June 1, 1942. Opinion of the Supreme Court The Court held unanimously that the Act violated the Equal Protection Clause of the Fourteenth Amendment, because white-collar crimes, such as embezzlement, were excluded from the Act's jurisdiction. Justice William O. Douglas concluded: Furthermore, because of the social and biological implications of reproduction and the irreversibility of sterilization operations, Justice Douglas also stressed that compulsory sterilization laws in general should be held to strict scrutiny: In a separate concurring opinion, Chief Justice Harlan F. Stone stated that while he concurred with Justice Douglas's opinion, he believed that, in his opinion, the Act violated Due Process Clause, specifically procedural due process, more than it violated the 14th Amendment. His main argument was that in order for legislation to convict and sterilize the defendant, there needed to be proof that criminal behavior could be inherited genetically, which the court had no proof of at the time. He cited Buck v. Bell, saying that because it has been proven that feeblemindedness is inheritable, sterilization is acceptable, but in the case of Skinner v. Oklahoma, it was not. Aftermath The only types of sterilization which the ruling immediately ended were punitive sterilization; it did not directly comment on compulsory sterilization of the mentally disabled or mentally ill and was not a strict overturning of the Court's ruling in Buck v. Bell (1927). Furthermore, most of the over 64,000 sterilizations performed in the US under the aegis of eugenics legislation were not in prison institutions or performed on convicted criminals; punitive sterilizations made up only negligible amounts of the total operations performed, as most states and prison officials were nervous about their legal status, which were not affirmed in Buck v. Bell specifically, as possible violations of the Eighth ("cruel and unusual punishment") or Fourteenth Amendments ("Due Process" and "Equal Protection Clauses"). Compulsory sterilizations of the mentally disabled and mentally ill continued in the US in significant numbers until the early 1960s. Although many of their laws stayed on the books for many years longer, the last known forced sterilization in the United States occurred in 1981 in Oregon. Federal law prohibits use of federal funds to sterilize "any mentally incompetent or institutionalized individual", but states including California use state funds for tubal ligations. A 2013 report showed that between 2006 and 2010, at least 148 women were sterilized after childbirth while incarcerated in two California prisons.