Many modern researchers, such as DeLisi (2012), have branded Lombroso and his atavistic theory as racist. For example, just because an individual had certain atavistic characteristics, does not mean that they are or are destined to become criminal. Following this logic, it appears that certain races are more likely to become criminal than others, such as African Americans, amongst whom curly hair is common. Therefore, this may have lended itself to giving ‘scientific justification’ for discriminatory practices and eugenics e.g. William Shockley’s Voluntary Sterilization Bonus Plan.