Theresa Marie Schindler Schiavo v. Michael Schiavo
2005 U.S. App. LEXIS 4867, 403 F.3d 1289 (2005)
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Rule of Law:
The decision to withhold life-sustaining nutrition and hydration by a private guardian, pursuant to a valid state court order, does not create a federal cause of action under the Americans with Disabilities Act, the Rehabilitation Act, or the Eighth and Fourteenth Amendments. Federal courts will not grant emergency injunctive relief in such cases without a substantial showing of a meritorious federal claim.
Facts:
- Theresa Marie Schindler Schiavo was incapacitated and required a feeding tube for nutrition and hydration to sustain her life.
- Her husband and court-appointed guardian, Michael Schiavo, asserted that Theresa would not have wished to be kept alive in her condition.
- Theresa's parents, Robert and Mary Schindler, disputed Michael Schiavo's assertion and sought to have her care continued.
- After extensive litigation, Florida state courts authorized Michael Schiavo to have Theresa's nutrition and hydration tube removed.
- Pursuant to the state court order, the Hospice of the Florida Suncoast, Inc., where Theresa was a patient, removed the tube.
Procedural Posture:
- After extensive state court litigation, Florida courts authorized the removal of Theresa Schiavo's nutrition and hydration tube.
- Theresa's parents, Robert and Mary Schindler, filed suit on her behalf in the U.S. District Court for the Middle District of Florida, seeking a temporary restraining order (TRO) to have the tube reinserted.
- The district court denied the Schindlers' first TRO motion.
- The Schindlers appealed to the U.S. Court of Appeals for the Eleventh Circuit, which affirmed the district court's denial in a prior decision (Schiavo I).
- The Schindlers filed an amended complaint in the district court, adding five new federal claims.
- Based on the new claims, the Schindlers filed a second motion for a TRO.
- The district court denied the second TRO motion.
- The Schindlers (appellants) appealed the denial of their second TRO motion to the U.S. Court of Appeals for the Eleventh Circuit, with Michael Schiavo and the Hospice (appellees) defending the district court's decision.
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Issue:
Do the parents of Theresa Schiavo demonstrate a substantial case on the merits that the removal of her nutrition and hydration, pursuant to a state court order, violates her rights under the Americans with Disabilities Act, the Rehabilitation Act, or the Eighth and Fourteenth Amendments to the U.S. Constitution, thereby warranting a temporary restraining order?
Opinions:
Majority - Per Curiam
No. The plaintiffs have not shown a substantial case on the merits for any of their federal claims. The Americans with Disabilities Act (ADA) and the Rehabilitation Act do not apply because neither Michael Schiavo nor the Hospice are state actors or public entities discriminating based on disability; they are private parties complying with a valid court order. The Eighth Amendment's prohibition on cruel and unusual punishment is inapplicable as it only pertains to criminal convictions, not medical treatment decisions. Finally, there is no Fourteenth Amendment due process violation, as the Supreme Court's decision in Cruzan does not mandate a 'clear and convincing evidence' standard, and even if it did, Florida state courts applied that very standard, affording more than sufficient procedural due process.
Concurring - Wilson, Circuit Judge
No. The plaintiffs have been unable to present any new claims in their amended complaint that palpably allege a violation of a right secured by the U.S. Constitution or federal law.
Analysis:
This decision underscores the significant deference federal courts give to state court proceedings, particularly in the realm of family law and end-of-life care. By strictly applying the 'state action' doctrine and narrowly construing the scope of federal disability statutes and constitutional protections, the court severely limited the avenues for federal intervention in such disputes. The ruling reinforced that a disagreement with a state court's factual findings or outcome does not, by itself, constitute a federal due process violation, thereby upholding principles of federalism and finality.
