In the Matter of Karen Ann Quinlan: 1975

Plaintiff: Joseph T. Quinlan
Defendant: St. Clare's Hospital
Plaintiff Claim: That doctors at St. Clare's Hospital should obey Mr. Quinlan's instructions to disconnect his comatose daughter from her respirator and allow her to die
Chief Defense Lawyers: Ralph Porzio (for Karen Quinlan's physicians), Theodore Einhorn (for the hospital), New Jersey State Attorney General William F. Hyland, and Morris County Prosecutor Donald G. Collester, Jr.
Chief Lawyers for Plaintiff: Paul W. Armstrong and James Crowley
Judge: Robert Muir, Jr.
Place: Morristown, New Jersey
Date of Decision: November 10, 1975
Decision: Denied Mr. Quinlan the right to authorize termination of "life-assisting apparatus" and granted Karen Quinlan's physicians the right to continue medical treatment over the objections of the Quinlan family. Overturned by the New Jersey Supreme Court, which, on March 31, 1976, ruled that Karen's "right of privacy" included a right to refuse medical treatment and that her father, under the circumstances, could assume this right in her stead.

SIGNIFICANCE: This case prompted the adoption of "brain death" as the legal definition of death in some states and the adoption of laws recognizing "living wills" and the "right to die" in other states, as well as the formation of "bioethics" committees in many hospitals. In 1985, the New Jersey Supreme Court ruled that all life-sustaining medical treatment—including artificial feeding—could be withheld from incompetent, terminally ill patients, provided such action was shown to be consistent with the afflicted person's past wishes.

On April 15, 1975, 21-year-old Karen Ann Quinlan passed out and lapsed into a coma after sustaining bruises which were never satisfactorily explained and ingesting tranquilizers "in the therapeutic range" with alcohol. Unable to breathe on her own, she was placed on a respirator.

By the following autumn, Quinlan's family and doctors had given up hope of recovery. Her parents, Julia and Joseph Quinlan, were devout Roman Catholics. The Quinlans consulted their parish priest, Father Thomas Trapasso, and were told that they could, in good conscience, request that Karen be removed from the respirator. The request was made, but Karen's primary physician, Dr. Robert Morse, refused to end the artificial support. Joseph Quinlan went to court.

By the time the trial began on October 20, 1975, a lawyer, Daniel R. Coburn, had become the court-appointed guardian for Karen Quinlan and both Morris County Prosecutor Donald G. Collester, Jr., and State Attorney General William F. Hyland had intervened, or joined the case, in an attempt to uphold New Jersey's homicide statutes. During pretrial interviews, Attorney General Hyland had portrayed the case as a challenge to New Jersey's long-standing definition of death as the "cessation of vital signs" and one which could result in a new definition based on "cerebral" or "brain death."

The week before the trial, however, it was disclosed that Karen Quinlan did not have a "flat" electroencephalograph, a medical test which would have been evidence of a complete absence of brain-wave activity. She also was capable of breathing on her own for short, irregular periods and had occasionally shown muscle activity which some doctors had described as voluntary. It immediately became clear that the trial would not center on New Jersey's definition of death but on an even more complicated question of whether Karen Quinlan had a "right to die."