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During the late 1800s through the early 1900s, physicians administered pelvic massages involving clitoral stimulation by early electronic vibrators as treatments for what was called female hysteria. Until the early 1900s, physicians used female hysteria as a diagnosis for women who reported a wide range of complaints and symptoms unexplainable by any other diagnosis at the time. According to historian Rachel Maines, physicians provided pelvic massages for thousands of years to female patients without it being considered erotic or sexually stimulating.
In 1942, the United States Supreme Court Case of Skinner v. Oklahoma ruled that states could not legally sterilize those inmates of prisons deemed habitual criminals. Skinner v. Oklahoma was about the case of Jack Skinner, an inmate of the Oklahoma State Penitentiary in McAlester, Oklahoma, who was subject to sterilization under the Oklahoma Habitual Criminal Sterilization Act of 1935. The case, decided on 1 June 1942, determined that state laws were unconstitutional if those laws enabled states to forcibly sterilize inmates deemed to be habitual criminals.