In the 1996 case of "Fieger v. Thomas", the United States Court of Appeals for the Sixth Circuit both recognized and criticized "Buck v. Bell" by writing "as Justice Holmes pointed out in the only part of "Buck v. Bell" that remains unrepudiated, a claim of a violation of the Equal Protection Clause based upon selective enforcement 'is the usual last resort of constitutional arguments. In 2001, the United States Court of Appeals for the Eighth Circuit cited "Buck v. Bell" to protect the constitutional rights of a woman coerced into sterilization without procedural due process. The court stated that error and abuse will result if the state does not follow the procedural requirements, established by "Buck v. Bell", for performing an involuntary sterilization.