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In the Matter of Karen Ann Quinlan: 1975

Decision Is Appealed



On November 10, 1975, Judge Muir rendered his decision. He refused permission for the removal of the respirator and appointed Daniel R. Coburn to continue acting as the guardian of Karen's "person." Joseph Quinlan was appointed guardian of his daughter's property. Rejecting the Quinlans' plea that their daughter be allowed to pass into life after death, Muir wrote that disconnecting the respirator "is not something in her best interest, in a temporal sense, and it is in a temporal sense that I must operate, whether I believe in life after death or not. The single most important temporal quality that Karen Ann Quinlan has is life," he continued. "This Court will not authorize that life to be taken away from her."



On November 17, 1975, the Quinlans filed an appeal, which the New Jersey Supreme agreed to hear on an "accelerated schedule."

On January 26, 1976, during a three-hour session, the case was argued before the seven justices of New Jersey's highest court. Their unanimous decision-naming Joseph Quinlan guardian and authorizing him to order removal of the respirator—was rendered on March 31. Chief Justice Richard J. Hughes wrote the opinion. He specifically stated that the ruling was not based on the freedom of religion argument favored by the Quinlans: "Simply stated, the right to religious beliefs is absolute but conduct in pursuance therefore is not wholly immune from governmental restraint."

Instead, Chief Justice Hughes cited the Supreme Court's decision in the Griswold v. Connecticut birth-control case and based the decision on "Karen's right to privacy." It was a right, he continued, that could "be asserted on her behalf by her guardian under the peculiar circumstances here present."

Lastly, Justice Hughes dismissed the attorney general's and the Morris County prosecutor's contentions that the person removing Quinlan's respirator should be charged with homicide upon her death:

[T]he exercise of a constitutional right, such as we here find, is protected from criminal prosecution. We do not question the state's undoubted power to punish the taking of human life, but that power does not encompass individuals terminating medical treatment pursuant to their right of privacy.

Neither the hospital, Karen Quinlan's physicians, nor the State of New Jersey chose to appeal the decision to the Supreme Court. Quinlan's respirator was removed in May 1976. She managed to breathe on her own and remained in a coma for 10 more years. She died on June 11, 1985.

Kathryn Cullen-DuPont

Suggestions for Further Reading

Colen, B.D. Karen Ann Quinlan. New York: Nash, 1976.

New York Times: September 14, 16, 17, 20, 22, 23, 24, 25, 26, 28, 1975; October 1, 3, 8, 10, 11, 12, 13, 14, 15, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 1975; November 2, 5, 8, 9, 11, 12, 16, 18, 21, 23, 25, 26, 28, 29, 1975; December 7, 12, 17, 18, 19, 22, 1975; January 19, 26, 27, 1976; February 25, 1976; March 9, 1976; April 1, 2, 7, 8, 9, 10, 12, 13, 1976; May 2, 6, 7, 22, 24, 25, 26, 27, 28, 29, 30, 1976; June 12, 1985.

Quinlan, Joseph. Karen Ann: The Quinlans Tell Their Story. Garden City, N.Y.: Doubleday & Co., 1977.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1973 to 1980In the Matter of Karen Ann Quinlan: 1975 - Accepted Standards Vs. Right To Die, Decision Is Appealed, Suggestions For Further Reading