Sterilization rates under eugenic laws in the United States climbed from 1927 until "Skinner v. Oklahoma", 316 U.S. 535 (1942). While "Skinner v. Oklahoma" did not specifically overturn "Buck v. Bell", it created enough of a legal quandary to discourage many sterilizations. By 1963, sterilization laws were almost wholly out of use, though some remained officially on the books for many years. Language referring to eugenics was removed from Virginia's sterilization law, and the current law, passed in 1988 and amended in 2013, only authorizes the voluntary sterilization of those 18 and older, after the patient has given "written consent" and the "doctor" has informed the "patient" of the "consequences" as well as "alternative methods of contraception".