Okay, so this had me curious enough to look it up... somewhere OTHER than the internet. With all due respect Kyle, if you're trying to prove something, don't quote internet sites as your resources. They teach us that here in the 'lame' midwest... (along with the proper use of the YOU'RE conjunction.)
Anyway, only ONE of my books describes the toe count on Terrapene carolina species. Here is an excerpt:
THREE-TOED BOX TURTLE
Terrapene carolina triumguis
Identification: 4.5-5 in.; record 7 in. Don't depend entirely on the toes--it sometimes has four! The Florida Box Turtle also usually has only three toes on each hind foot, and so do occasional specimens of all other subspecies. Concavity in plastron of males very shallow or absent. A marked tendency for pattern to be replaced (sometimes completely) by plain olive- or horn-colored areas; plastron often plain yellow or horn-colored. Orange or yellow spots usually conspicuous on both head and forelimbs. ... Range: Mo. to Tx and s.-cen. Ala.
EASTERN BOX TURTLE
Terrapene carolina carolina
Identification: 4.5 - 6 in.; record 7 13/16 in. A "land turtle" with a high, domelike shell and an extremely variable coloration and pattern. Both upper and lower shells may be yellow, orange, or olive on black or brown; either dark or light colors may predominate. Four toes on each hind foot. Male: rear lobe of plastron with central concave are; eyes sometimes red. Female: Plastron flat or slightly convex; eyes normally brown. Young: shell much flatter; mostly plain grayish brown, but with spot of yellow on each large scute. ... Range: Ne. Mass. to Ga., west to Mich., Ill., and Tenn. Within the U.S. this and all other races of Terrapene carolina intergrade with one another in most areas where their ranges come in contact; two other races occur in Mexico.
Both of these descriptions are from a Peterson Field Guide: Reptiles and Amphibians of Easter/Central North America. Another subspecies listed in the book is the Gulf Coast Box Turtle, Terrapene carolina bauri, and it is described as having four toes. I now understand why there is such confusion when it comes to the common names of this species. Since their ranges overlap, and each 'race' can be so variable, why would one want to call a four-toed specimen a "three-toed box turtle?" Given these descriptions, it would be MY opinion (for what it's worth) that since there are multiple subspecies, and they are each individually variable, that the animals with three toes on the rear feet should be considered "three-toed box turtles". Otherwise I think it should fall under one of the other subspecies.