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Vacco v. Quill

Supreme Court of the United States · 1997 · Constitutional Law

Constitutional LawEqual ProtectionPhysician-Assisted SuicideRefusal of Medical TreatmentEqual Protection Clauserational basisassisted suiciderefusal of treatment

Facts

New York makes it a crime to intentionally cause or aid another person to commit or attempt suicide, but it permits competent patients to refuse unwanted lifesaving medical treatment. Respondent physicians alleged that prescribing lethal medication to mentally competent, terminally ill patients in great pain would be consistent with their medical practice, but that New York's assisted-suicide ban deterred them from doing so. Respondents argued that refusal of life-sustaining treatment is essentially the same as physician-assisted suicide and that New York therefore treated similarly situated terminally ill patients differently. The Second Circuit accepted that view and held the ban irrational as applied to mentally competent, terminally ill persons in the final stages of illness.

Issue

Does New York's prohibition on assisting suicide violate the Equal Protection Clause because New York allows competent patients to refuse life-sustaining medical treatment? More specifically, may the State constitutionally treat refusal of treatment differently from physician-assisted suicide?

Rule

Under the Equal Protection Clause, if a law neither burdens a fundamental right nor targets a suspect class, it is valid so long as it bears a rational relation to some legitimate end. A State may, consistent with equal protection, distinguish between a competent person's refusal of unwanted lifesaving medical treatment and physician-assisted suicide, because that distinction is rational and longstanding.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, a statute makes it a felony for any person to intentionally provide lethal medication so that another person can end his own life. Ohio also recognizes the right of a competent adult to refuse a ventilator, dialysis, or artificial nutrition. Nina Carver, a terminally ill patient in Cleveland, argues that the statute violates equal protection because it lets some dying patients hasten death by stopping treatment but bars her physician from prescribing fatal pills.

Which is the strongest response to Nina's equal protection claim?

Explanation. Under the majority opinion, when a law neither burdens a fundamental right nor targets a suspect class, it is reviewed under rational basis. A State may rationally distinguish a competent person's refusal of unwanted life-sustaining treatment from physician-assisted suicide. The Equal Protection Clause does not create a substantive right to hasten death, and the distinction is supported by differences in causation, intent, and legitimate state interests.