Science and Law: Quinlan v. State of New Jersey: Do patients have the right to end life-sustaining care based on the U.S. Constitution?

May 9, 2015

Science and Law

gavel


QUINLAN v. STATE OF NEW JERSEY
Supreme Court of New Jersey
70 N.J. 10, 355 A. 2d 647, 1976

This case is another important landmark decision in the ‘right to die’ movement. This helped to define the rights of patients and their guardians to refuse or discontinue life-sustaining medical intervention.

Case Background

  • Karen Ann Quinlan was 21 when she attended a party where she consumed diazepam, detropropoxyphene, and alcohol, a dangerous mixture of chemicals that caused her to collapse after she returned home.
  • Quinlan stopped breathing twice for more than 15 minutes, and after she was taken to a hospital, she ended up lapsing into a persistent vegetative state, requiring a ventilator to keep her alive.
  • However, her medical condition was not straightforward, and was documented as follows:
    • Her EEG (electroencephalogram, the test for electrical activity in the brain) was abnormal, but confirmed that she wasn’t brain dead since she had a small amount of activity in her brain stem.
    • She was “alive” according to the standards used in a Harvard Medical School Ad Hoc Committee 1968 report
    • Her brain showed periods of what seemed to be “sleep-like” and awake unresponsiveness.
    • She clearly had no awareness of her surroundings utilizing higher brain function, although spinally mediated instinctual motions, such as reacting to light, blinking, and moving could still occur
    • She was kept alive with a nasal-gastro tube, but her body was becoming emaciated.
    • Quinlan remained in a fetal position, and the muscles in her limbs were all extremely rigid.
  • Karen Quinlan’s father, Joseph Quinlan sought appointment as her legal guardian and permission to end her life-sustaining care.
  • Joseph Quinlan’s was a devout Catholic, and he consulted with his church before making his request.
  • Based on Pope Pius XII’s 1957 “allocutio” to anesthesiologists, the respirator constituted an “extraordinary” means of treatment, and also that removing the respirator was only an indirect cause of death, making it a permissible action by the Catholic faith.

What issues are being debated?

  • Does the substantive due process right to privacy mean that a patient has the right to refuse intrusive medical treatment?
  • Does the substantive due process right to privacy also include actions of third parties whose involvement is necessary for a patient to exercise a constitutional right?
  • Does the father’s religious freedom override the state interest in the preservation of life?
  • Can the hospital or doctors involved in Karen Quinlan’s care be prosecuted for removing her life support?
  • Looking at the issue from a broader perspective, can letting a patient die be considered in their best interest in an age where medical technology can keep her organs functioning, but not restore her higher brain function?

How was the law interpreted and applied?

  • The New Jersey Supreme Court ruled that the right to privacy does include a right to refuse life-sustaining care, and protects the third parties involved.
  • The court also determined that the father’s religious freedom does not override the state’s interest in preservation of life. (Supporting this argument would have set a dangerous precedent with regard to cases of child abuse or neglect involving religious practices.)
  • The New Jersey Supreme Court overturned the decision of the trial court, and appointed Joseph Quinlan to be Karen Quinlan’s legal guardian, and released all involved parties from civil or criminal liability if they chose to end her care.
  • The court also ruled that in this case any statements made by the patient while competent lack probative weight. This is a standard that varies state by state, since some states will allow casual conversations to serve as evidence of a patient’s wishes.

Aftermath and further analysis

  • Although the New Jersey Supreme Court ruled that patients and their guardians could refuse any kind of life-sustaining treatment, including feeding tubes, hydration, and respirators, the Quinlans only requested to remove the respirator.
  • After removing the respirator, Karen Quinlan surprisingly could breath on her own. It seems that the hospital staff had been slowly weaning her off of the respirator, and so she did not pass away from having the respirator removed, which highlights an important difference between withdrawing care and active euthanasia.
  • After a short battle with pneumonia, Karen Ann Quinlan passed away at 7:01 PM on June 11, 1985 at the age in 31. She was in her room at the Morris View Nursing Home with her mother, Julia Quinlan at her bedside.
  • While the parents did not chose to end her feeding or hydration, their case established a precedent for all future cases involving end of life care and medical futility, such as Cruzan v. Director and the Terry Schiavo case.

For more information see:

http://www.nytimes.com/1985/06/12/nyregion/karen-ann-quinlan-31-dies-focus-of-76-right-to-die-case.html

Bioethics and Public Health Law by Orentlicher, Bobinski, and Hall

http://www.cobar.org/index.cfm/ID/1818/subID/6629/CLPE/Quinlan-Brief/

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About jslachman381

I'm a Yale graduate who majored in History of Science, Medicine, and Public Health.

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One Comment on “Science and Law: Quinlan v. State of New Jersey: Do patients have the right to end life-sustaining care based on the U.S. Constitution?”

  1. DAL Says:

    Very interesting

    The ethical challenges we face are complicated by advances in technology and our increased ability to sustain some body function for months. . While religious conservatives often stampede before the media to promote maintaining essentially dead people they concurrently reduce programs that actually improve the quality of life for the living

    DAL

    Like

    Reply

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