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. Such laws violated the Equal Protection Clause of the Fourteenth Amendment to the US Constitution. The Skinner v. Oklahoma decision also reflected tensions in US eugenic policies when juxtaposed against similar policies of the Nazi regime in Europe, especially with regard to sterilization measures.
Tomorrow's Children is a film that tells the story of Alice Mason, a young woman whom the US government forcibly sterilizes because she comes from a family with a history of alcoholism, mental illnesses, and physical disabilities, traits that they considered biologically determined and inferior. The film, released in 1934, was directed by Crane Wilbur, produced by Bryan Foy, written by Wilbur and Wallace Thurman, and released by Foy Productions Ltd. Tomorrow's Children criticized forced sterilization and the eugenics movement in the United States in addition to protesting film censorship regulations in the early 1900s.