Washington v. Glucksberg

Brief Fact Summary.

Respondent challenges the Washington’s prohibition against causing or aiding a suicide.

Synopsis of Rule of Law.

A State may prohibit causing or aiding a suicide if it shows that its ban is rationally related to legitimate government interests.

Facts.

The State of Washington prohibits causing or aiding a suicide. The Ninth Circuit held that the State’s assisted-suicide ban was unconstitutional as applied to terminally ill competent adults who wish to hasten their death with medication prescribed by their physicians.

Issue.

Does Washington’s prohibition against causing or aiding a suicide offends the Fourteenth Amendment?

Held.

No, the decision to commit suicide with the assistance of another may be just as personal and profound as the decision to refuse unwanted medical treatment, but it has never enjoyed similar legal protection. Washington has an unqualified interest in the preservation of human life and in protecting the integrity and ethics of the medical profession. The State’s interest goes beyond protecting the vulnerable populations from coercion. The state’s interests legitimize its decision to ban assisting suicide.

Discussion.

The asserted right to assistance in committing suicide is not fundamental liberty interest protected by the Due Process Clause. The Constitution also requires, however, that Washington’s assist-suicide ban be rationally related to legitimate government interests. Washington has shown that it has an interest in protecting vulnerable groups – including the poor, the elderly, and disabled persons – from abuse, neglect and mistakes. The risk of harm is greatest for the many individuals in our society whose autonomy and well-being are already compromised by poverty, lack of access to medicare care. If physician-assisted suicide were permitted, many might resort to it to spare their families in substantial financial burden of end of life health-care costs. Moreover, the state interest extends to protecting disabled and terminally ill people from prejudice, negative and inaccurate stereotypes. Finally, the State may fear that permitting assisted suicide will start it down the path to voluntary and even involuntary euthanasia. Therefore, this state law does not violate the Fourteenth Amendment.