Vacco v. Quill
521 U.S. 793 (1997)
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Rule of Law:
A state's prohibition on assisting suicide does not violate the Fourteenth Amendment's Equal Protection Clause, because the distinction between withdrawing life-sustaining treatment and assisting suicide is a rational one which the state is entitled to recognize.
Facts:
- Under New York law, it is a crime for a person to intentionally cause or aid another person to commit suicide.
- New York law also permits a competent person to refuse any medical treatment, including lifesaving treatment.
- Dr. Timothy Quill and other New York physicians practice medicine and regularly treat mentally competent, terminally ill patients.
- Some of these terminally ill patients experience great pain and suffering and have expressed a desire for physician-assisted suicide.
- The physicians asserted that providing lethal medication to such patients would be consistent with their professional standards, but they were deterred from doing so by New York's assisted-suicide ban.
- Three terminally ill patients joined the physicians' lawsuit, stating they wished to have the option of self-administering lethal medication prescribed by a doctor.
Procedural Posture:
- Dr. Timothy Quill, other physicians, and three patients (respondents) sued the New York Attorney General, Vacco (petitioner), in the U.S. District Court for the Southern District of New York.
- The respondents challenged New York's assisted-suicide ban, arguing it violated the Fourteenth Amendment's Equal Protection Clause.
- The District Court ruled in favor of New York, finding the ban constitutional.
- The respondents appealed to the U.S. Court of Appeals for the Second Circuit.
- The Second Circuit reversed the District Court's decision, holding that the New York law violated the Equal Protection Clause.
- The petitioner, Vacco, sought and was granted a writ of certiorari from the Supreme Court of the United States.
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Issue:
Does New York's statutory prohibition on physician-assisted suicide violate the Equal Protection Clause of the Fourteenth Amendment by treating terminally ill patients who wish to hasten their death with lethal medication differently from those who can hasten their death by refusing life-sustaining medical treatment?
Opinions:
Majority - Chief Justice Rehnquist
No, New York's prohibition on assisting suicide does not violate the Equal Protection Clause. The law treats everyone alike by permitting anyone to refuse medical treatment and prohibiting anyone from assisting a suicide. The distinction between allowing a patient to die from their underlying illness by refusing treatment and intentionally causing a patient's death through lethal medication is a rational and well-established legal and medical principle. This distinction is based on the concepts of causation—where the underlying disease is the cause of death when treatment is refused, versus a lethal drug being the cause in assisted suicide—and intent, where a physician withdrawing treatment aims to respect patient autonomy, not cause death. The state has legitimate interests in preserving life, preventing suicide, protecting vulnerable groups, and maintaining the integrity of the medical profession, all of which are rationally served by the ban.
Concurring - Justice O'Connor
Justice O'Connor concurred in the judgment, joined by Justices Ginsburg and Breyer in part. She emphasized that while there is no generalized right to 'commit suicide,' the Court's holding does not preclude a more particularized challenge by a terminally ill patient experiencing great suffering. She noted that state legislatures are currently the more appropriate venue for this difficult debate, as they can craft careful procedures and safeguards. O'Connor stressed that dying patients have a constitutionally protected interest in obtaining relief from pain, even if it hastens death, distinguishing this from assisted suicide where death itself is the intended outcome.
Concurring - Justice Stevens
Justice Stevens concurred in the judgment but wrote separately to emphasize that while the facial challenge to New York's law fails, there might be individual cases where the Constitution requires exceptions. He argued that the liberty interest at stake is not a general right to suicide but rather the right of terminally ill patients to make decisions about the end of their lives. Stevens suggested that in some circumstances, a blanket prohibition might be arbitrary when applied to competent, terminally ill patients experiencing unbearable pain. He left open the possibility that future as-applied challenges might succeed in specific cases.
Concurring - Justice Souter
Justice Souter concurred in the judgment. He referenced his separate opinion in the companion case, Washington v. Glucksberg, stating that the same reasons that lead him to conclude the prohibition on assisted suicide is not arbitrary under the Due Process standard also support the distinction between assistance to suicide and practices like terminating life support. Therefore, the distinction does not violate the Equal Protection Clause.
Analysis:
This decision, along with its companion case Washington v. Glucksberg, definitively held that there is no constitutionally protected right to physician-assisted suicide. By applying the lenient rational basis review, the Court gave significant deference to state legislatures to regulate or prohibit the practice. The ruling solidified the legal distinction between 'letting die' (withdrawing treatment) and 'killing' (assisted suicide), thereby preventing the Equal Protection Clause from being used to compel states that allow the former to also permit the latter. This has kept the debate over end-of-life options largely within the political and legislative arenas rather than the judicial one.
