 Sexual selection became a central focus for race-thinking with the introduction of the term “eugenics” in 1883 by Francis Galton (1822–1911) in his essay “Inquiries into Human Faculty and Development” (Hannaford 1996, 290). Focusing on physical as opposed to “moral” qualities, Galton advocated selective breeding to improve the “health, energy, ability, manliness, and courteous disposition” of the human species in his later essay “Eugenics: Its Definition, Scope, and Aims” (Bernasconi and Lott 2000, 80). Following the same currents of “Social Darwinism” that advocated the evolutionary improvement of the human condition through active human intervention, Galton proposed making eugenics not only an element in popular culture or “a new religion” (Bernasconi and Lott 2000, 82) but even a policy enforced by the American government. While positive eugenics, or the enforced breeding of higher types, never became law, negative eugenics, or the sterilization of the feebleminded or infirm, did become public policy enforced by a number of American states and upheld by the United States Supreme Court in an eight-to-one decision in Buck v. Bell (274 U.S. 200, 1927). The widespread acceptance of negative eugenics can be inferred by the fact that the Court Opinion justifying the decision was authored by Justice Oliver Wendell Holmes, a figure usually associated with progressive and civil libertarian positions, and whose doctrine of “clear and present danger” sought to expand the protection of free speech.