Vacco v. Quill

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1997 United States Supreme Court case

Vacco v. Quill, 521 U.S. 793 (1997), is a landmark decision of the Supreme Court of the United States regarding the right to die . It ruled 9–0 that a New York ban on physician-assisted suicide was constitutional, and preventing doctors from assisting their patients, even those terminally ill and/or in great pain, was a legitimate state interest that was well within the authority of the state to regulate. In brief, this decision established that, as a matter of law, there was no constitutional guarantee of a "right to die."

Background

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The State of New York had enacted a prohibition against physician-assisted suicide, making it a crime for a physician to administer lethal medication or to otherwise knowingly and intentionally end the life of a patient, even a consenting, mentally competent, and terminally ill patient.

A number of physicians (here the respondents ) filed suit against New York's Attorney General , in the United States District Court for the Southern District of New York , challenging the law on constitutional grounds. The respondents argued that the statute violated the Equal Protection Clause of the Fourteenth Amendment , noting that a patient, while still enjoying the right to refuse treatment when terminally ill, did not enjoy the right to authorize a doctor to end their life. In effect, the respondents argued that refusing treatment and requesting that their doctor assist them in ending their life were "the same thing."

The District Court ruled in favor of the New York statute. In its decision, the court stated that the State of New York had a rational, legitimate interest in preserving life and protecting vulnerable persons; as such, the law was not unconstitutional. The District Court said that this was a matter of legislation, and, if the ban were to be repealed, it would take an act of New York's legislature (or a binding referendum by the voters) to do so.

The United States Court of Appeals for the Second Circuit reversed the District Court's judgment. The Appeals Court reasoned that, even though the law itself applied as a general rule to all persons, a fact that the District Court noted in determining its constitutionality, it did not treat all competent patients equally when they were near death and wished to end their lives. To this effect, the Appeals Court said that, for example, a patient attached to a life support device was allowed to require its removal, while a person under identical circumstances could not demand that a doctor administer drugs to ensure the patient's death. It agreed with the contention that removing life support devices was identical to requesting physician-assisted euthanasia, and thereby reversed the lower court's finding.

The Supreme Court of the United States granted certiorari , hearing arguments on January 8, 1997.

Supreme Court decision

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On June 26, 1997, the Supreme Court issued six different opinions in a unanimous (9–0) decision. The majority opinion was authored by Chief Justice Rehnquist , and was joined by Justices O'Connor , Scalia , Kennedy , and Thomas . Justice O'Connor wrote a concurring opinion, joined in part by Justices Ginsburg and Breyer . Justices Stevens , Souter , Ginsburg , and Breyer filed separate concurring opinions.

The Court began its opinion by stating that the New York law did not infringe upon a fundamental right. In this line of reasoning, the Court referenced _San Antonio School District v. Rodriguez _, 411 U.S. 1 (1973), which said, in relevant part, that the judiciary must look to the Constitution, rather than to the stated "importance" of a right, when determining whether that right was, indeed, fundamental. Because New York's ban did not infringe upon a fundamental right, and because respondents were not claiming that the "right to die" was fundamental, the Court reiterated its policy of according such laws a great deal of leeway. In the Court's own words, from _Heller v. Doe _, 509 U.S. 312 (1993), laws such as those enacted by New York were entitled to a "strong presumption of validity."

After addressing the matter of fundamental rights, the Court delineated the rationale behind its decision. It first turned to the long-standing legal tradition of looking to a person's intent as a way of distinguishing between two acts with identical physical consequences. For example, a person who accidentally kills a pedestrian while blinded by the sun might only face punishment for vehicular manslaughter , while a person who intentionally and purposefully kills another with his car could be punished for murder . While these two acts give the same results, they are distinguished by the intent of the actors.

The Court applied the standard of intent to the matter at hand, finding that a doctor who withdraws life support at the request of his patient intends only to respect his patient's wishes. This, the Court said, is a sharp contrast to the doctor who honors a patient's request to end their life, which necessarily requires more than an intent to respect their wishes; namely, it requires the intent to kill the patient. A major difference, the Court determined, in the two scenarios is that the former may cause the patient to die from underlying causes, while the latter will cause the patient to die by the hands of the physician. To this effect the Court quoted a House Judiciary Committee hearing, stating that a physician performing an assisted suicide, "must, necessarily and indubitably, intend primarily that the patient be made dead." Furthermore, in another repudiation of the respondents' argument, the Court noted that a patient removing life support might not actually intend to die, and that death without such a device may not be a certainty.

Looking to New York's intent behind the ban, the Court noted that the law plainly recognized the difference between "killing" and "letting die ." It also recognized that the State of New York had, as a matter of policy, a compelling interest in forbidding assisted suicide, while allowing a patient to refuse life support was simply an act of protecting a common-law right. This right was not, contrary to the Court of Appeals' view, the "right to hasten death"; rather, the Court declared that it was the right to retain bodily integrity and to preserve individual autonomy. The prevention of "unwanted touching" was, the Court said, a very legitimate right to protect.

In closing, the Court said that it fully rejected the respondents' argument that the statutory difference between assisted suicide and refusing lifesaving treatment was "arbitrary" and "irrational." It did concede that there were probably incidents where the two were likely to have the same result, but also said that such an argument was beside the point. The Court declared that New York "obviously" had a number of legitimate, compelling, and rational interests in enacting this ban. However, regardless of these reasons, it determined simply that the law permitted everyone to refuse treatment and prohibited everyone from assisting suicide; as such, the law did not run afoul of the Equal Protection Clause and the state had the constitutional authority to put such a law into place.

O'Connor's concurrence

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Justice O'Connor joined the Court's decision. She accepted the contention that there was neither a "right to commit suicide" nor a "right to die," as such. She did not, however, think that the Court needed to consider the conflict beyond rejecting the facial challenges to the statute. Justice O'Connor stated that, in the context of the questions presented in this case, the Court did not need to address whether a patient had a constitutionally cognizable interest in controlling the circumstances of his or her imm

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