Petitioners
Dennis C. Vacco, Attorney General of New York, et al.
Respondents
Timothy E. Quill, Samuel C. Klagsbrun, Howard A. Grossman
Petitioners' Claim
That a ruling by the U.S. Court of Appeals for the Second Circuit invalidating a New York State statute banning physician-assisted suicide was incorrect.
Chief Lawyer for Petitioners
Barbara Gott Billet, Solicitor General; Daniel Smirlock, assistant Attorney General; Michael S. Popkin, Assistant Attorney General
Chief Lawyer for Respondents
Laurence H. Tribe, David J Burman, Carla A. Kerr, Peter J. Rubin, Kari Anne Smith, Kathryn L. Tucker
Justices for the Court
Stephen Breyer, Ruth Bader Ginsburg, Anthony M. Kennedy, Sandra Day O'Connor,William H. Rehnquist (writing for the Court), Antonin Scalia, David H. Souter, John Paul Stevens, Clarence Thomas
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
26 June 1997
Decision
Reversed the court of appeals to rule that New York State's ban on physician-assisted suicide did not violate the Equal Protection Clause of the Fourteenth Amendment.
Significance
The ruling provided constitutional sanction to state laws banning physician-assisted suicide. By determining that there was a qualitative legal differencebetween denying life-prolonging treatment to terminally ill patients and assisting in their death, the Court validated existing statutes in many states,and confirmed that states could draft laws banning assisted suicide that wereable to withstand constitutional scrutiny.
A Two-Edged Sword
Advances in medicine have extended human life expectancy dramatically in the1980s and 1990s. While this was generally viewed as a desirable development,medical science prolonged the lives of terminally ill people, even in cases where their quality of life was poor. As more people with terminal illness lived longer, many who suffered great pain or debilitation expressed a desire toend their suffering through death. Many individuals have sympathized with this outlook, including numerous members of the medical profession. As such, the possibility and reality of physician-assisted suicide has become a regularpart of popular debate and a focus of legislative activities.
In the early 1990s, New York State law forbade physicians from assisting terminally ill patients wishing to end their lives. Physicians were allowed, however, to deny life-prolonging treatment to those terminally ill patients who did not wish to receive it. Perceiving a logical incongruity in these statutesthree physicians, Timothy E. Quill, Samuel C. Klagsbrun, and Howard A. Grosman brought suit against the New York State Attorney General in U.S. DistrictCourt to invalidate the state's ban on assisted suicide.
Equal Protection?
The three physicians claimed that New York State law violated the Equal Protection Clause of the Fourteenth Amendment, since terminally ill patients receiving life-prolonging treatment could choose to die by ending said treatment,while others, who desired to end their lives but were not receiving life- prolonging treatment, could not choose to end their lives with medical assistance. The district court denied the physicians' claim, and the case proceeded tothe court of appeals.
The court of appeals reversed the decision of the district court, stating that "New York law does not treat equally all competent persons who are in the final stages of fatal illness and wish to hasten their death." In the court'sview, this unequal treatment resulted because "those in the final stages of aterminal illness who are on life support systems are allowed to hasten theirdeaths by directing the removal of such systems; but those who are similarlysituated, except for the previous attachment of life sustaining equipment, are not allowed to hasten death by self administering prescribed drugs." In other words, the court ruled that the removal of life support and suicide werenearly exactly equivalent. Following this setback the state of New York askedthe U.S. Supreme Court to accept the case on certiorari, and the Court heard arguments on 8 January 1997.
Omission and Commission
The Supreme Court ruled that New York state's ban on assisted suicide did notviolate the Equal Protection Clause of the Fourteenth Amendment. Justice Rehnquist, writing for the Court, rejected the court of appeals' conclusion thatremoval of life support and assistance with suicide were equivalent acts: "Unlike the Court of Appeals, we think the distinction between assisting suicide and withdrawing life sustaining treatment, a distinction widely recognizedand endorsed in the medical profession and our legal traditions, is both important and logical; it is certainly rational." This language was significant in that it allows states to differentiate their treatment of classes of peopleregardless of Fourteenth Amendment restrictions if they are able to show a reasonable and compelling reason for doing so. The Court went on to enumeratethe state's rationale for forbidding assisted suicide: "prohibiting intentional killing and preserving life; preventing suicide; maintaining physicians' role as their patients' healers; protecting vulnerable people from indifference, prejudice, and psychological and financial pressure to end their lives; and avoiding a possible slide toward euthanasia."
Impact
Vacco v. Quill established the interest of the state in prohibiting physicians from assisting in the suicide of terminally ill patients. By identifying a reasonable and compelling state interest in preventing assisted suicide, the Court removed any argument that terminally ill patients who are not onlife support might have had under the Equal Protection Clause of the Fourteenth Amendment. The ruling also provided a precedent for states struggling todevelop acceptable statutes outlawing assisted suicide. Despite this precedent, it has been extremely difficult for states in which assisted suicide has been practiced to prevent further occurrences, due in some measure to generalpublic support for the right of the dying to control their own demise.
Related Cases
States That Allow Assisted Suicide
Sources
Pertman, Adam. "Bills Aim to Disarm Oregon Law on Suicide." Boston Globe, 7 October 1998.
Dennis C. Vacco, Attorney General of New York, et al.
Respondents
Timothy E. Quill, Samuel C. Klagsbrun, Howard A. Grossman
Petitioners' Claim
That a ruling by the U.S. Court of Appeals for the Second Circuit invalidating a New York State statute banning physician-assisted suicide was incorrect.
Chief Lawyer for Petitioners
Barbara Gott Billet, Solicitor General; Daniel Smirlock, assistant Attorney General; Michael S. Popkin, Assistant Attorney General
Chief Lawyer for Respondents
Laurence H. Tribe, David J Burman, Carla A. Kerr, Peter J. Rubin, Kari Anne Smith, Kathryn L. Tucker
Justices for the Court
Stephen Breyer, Ruth Bader Ginsburg, Anthony M. Kennedy, Sandra Day O'Connor,William H. Rehnquist (writing for the Court), Antonin Scalia, David H. Souter, John Paul Stevens, Clarence Thomas
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
26 June 1997
Decision
Reversed the court of appeals to rule that New York State's ban on physician-assisted suicide did not violate the Equal Protection Clause of the Fourteenth Amendment.
Significance
The ruling provided constitutional sanction to state laws banning physician-assisted suicide. By determining that there was a qualitative legal differencebetween denying life-prolonging treatment to terminally ill patients and assisting in their death, the Court validated existing statutes in many states,and confirmed that states could draft laws banning assisted suicide that wereable to withstand constitutional scrutiny.
A Two-Edged Sword
Advances in medicine have extended human life expectancy dramatically in the1980s and 1990s. While this was generally viewed as a desirable development,medical science prolonged the lives of terminally ill people, even in cases where their quality of life was poor. As more people with terminal illness lived longer, many who suffered great pain or debilitation expressed a desire toend their suffering through death. Many individuals have sympathized with this outlook, including numerous members of the medical profession. As such, the possibility and reality of physician-assisted suicide has become a regularpart of popular debate and a focus of legislative activities.
In the early 1990s, New York State law forbade physicians from assisting terminally ill patients wishing to end their lives. Physicians were allowed, however, to deny life-prolonging treatment to those terminally ill patients who did not wish to receive it. Perceiving a logical incongruity in these statutesthree physicians, Timothy E. Quill, Samuel C. Klagsbrun, and Howard A. Grosman brought suit against the New York State Attorney General in U.S. DistrictCourt to invalidate the state's ban on assisted suicide.
Equal Protection?
The three physicians claimed that New York State law violated the Equal Protection Clause of the Fourteenth Amendment, since terminally ill patients receiving life-prolonging treatment could choose to die by ending said treatment,while others, who desired to end their lives but were not receiving life- prolonging treatment, could not choose to end their lives with medical assistance. The district court denied the physicians' claim, and the case proceeded tothe court of appeals.
The court of appeals reversed the decision of the district court, stating that "New York law does not treat equally all competent persons who are in the final stages of fatal illness and wish to hasten their death." In the court'sview, this unequal treatment resulted because "those in the final stages of aterminal illness who are on life support systems are allowed to hasten theirdeaths by directing the removal of such systems; but those who are similarlysituated, except for the previous attachment of life sustaining equipment, are not allowed to hasten death by self administering prescribed drugs." In other words, the court ruled that the removal of life support and suicide werenearly exactly equivalent. Following this setback the state of New York askedthe U.S. Supreme Court to accept the case on certiorari, and the Court heard arguments on 8 January 1997.
Omission and Commission
The Supreme Court ruled that New York state's ban on assisted suicide did notviolate the Equal Protection Clause of the Fourteenth Amendment. Justice Rehnquist, writing for the Court, rejected the court of appeals' conclusion thatremoval of life support and assistance with suicide were equivalent acts: "Unlike the Court of Appeals, we think the distinction between assisting suicide and withdrawing life sustaining treatment, a distinction widely recognizedand endorsed in the medical profession and our legal traditions, is both important and logical; it is certainly rational." This language was significant in that it allows states to differentiate their treatment of classes of peopleregardless of Fourteenth Amendment restrictions if they are able to show a reasonable and compelling reason for doing so. The Court went on to enumeratethe state's rationale for forbidding assisted suicide: "prohibiting intentional killing and preserving life; preventing suicide; maintaining physicians' role as their patients' healers; protecting vulnerable people from indifference, prejudice, and psychological and financial pressure to end their lives; and avoiding a possible slide toward euthanasia."
Impact
Vacco v. Quill established the interest of the state in prohibiting physicians from assisting in the suicide of terminally ill patients. By identifying a reasonable and compelling state interest in preventing assisted suicide, the Court removed any argument that terminally ill patients who are not onlife support might have had under the Equal Protection Clause of the Fourteenth Amendment. The ruling also provided a precedent for states struggling todevelop acceptable statutes outlawing assisted suicide. Despite this precedent, it has been extremely difficult for states in which assisted suicide has been practiced to prevent further occurrences, due in some measure to generalpublic support for the right of the dying to control their own demise.
Related Cases
- Morissette v. United States, 342 U.S. 246 (1952).
- United States v. Bailey, 444 U.S. 394 (1980).
- Cruzan v. Missouri Department of Health, 497 U.S. 261 (1990).
- Romer v. Evans, 517 U.S. 620 (1996).
States That Allow Assisted Suicide
- Oregon is the only state in which physician assisted suicide is legal.
- In 1994, Oregon became the first state to make it legal for physicians to prescribe lethal doses of drugs to terminally ill patients.
- InOctober of 1997, the Supreme Court refused to hear a challenge to Oregon's physician-assisted suicide law.
- Oregon's law only allows physicians toadminister life-ending drugs after a 15-day waiting period has elapsed.
- Attempts by other states such as New York and Washington to legalize physician-assisted suicides have not withstood legal challenges.
Sources
Pertman, Adam. "Bills Aim to Disarm Oregon Law on Suicide." Boston Globe, 7 October 1998.
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