Vacco v. Quill

Brief Fact Summary.

The petitioner challenged the New York statute that makes it a crime to aid another to commit or attempt suicide.

Synopsis of Rule of Law.

Equal Protection Clause creates no substantive rights but it embodies a general rule that States must treat like cases alike but may treat unlike cases accordingly.

Facts.

New York makes it crime to aid another to commit or attempt suicide, but patients may refuse even lifesaving medical treatment. It is alleged that New York’s prohibition on assisting suicide violates the Equal Protection Clause of the Fourteenth Amendment.

Issue.

Does New York’s prohibition on assisting suicide violate the Equal Protection Clause of the Fourteenth Amendment?

Held.

No, New York’s prohibition on assisting suicide does not violate the Equal Protection Clause of the Fourteenth Amendment, because the legislative classification or distinction neither burdens a fundamental right nor targets a suspect class and it bears a rational relationship to some legitimate end.

Concurrence.

Justice O’Connor

Everyone at some point may be affected by our own or a family member’s terminal illness. There is no reason to think the democratic process will not strike the proper balance between the interests of terminally ill, mentally competent individuals who seek to end their suffering and the State’s interest in protecting these who might seek to end their life mistakenly or under pressure.

Discussion.

Neither New York’s ban on assisting suicide nor its statutes permitting patients to refuse medical treatment treat anyone differently than anyone else or draw any distinctions between persons. Everyone, regardless of physical condition, is entitled, if competent, to refuse unwanted lifesaving medical treatment. no one is allowed to assist suicide. Laws that apply evenhandedly such as the one at issue to all unquestionably comply with the Equal Protection Clause. Further, a physician who withdraws or honors a patient’s refusal to begin, life sustaining medical treatment purposely intends only to respect his patient’s wishes and to cease doing useless and futile things to the patient when the patient no longer stands to benefit from them.