The effect of Buck v. Bell was to legitimize eugenic sterilization laws in the United States as a whole. While many states already had sterilization laws on their books, their use was erratic and effects practically non-existent in every state except for California. After Buck v. Bell, dozens of states added new sterilization statutes, or updated their constitutionally non-functional ones already enacted, with statutes which more closely mirrored the Virginia statute upheld by the Court.[22]