Citation. 521 U.S. 702, 117 S. Ct. 2302, 117 S. Ct. 2258, 138 L. Ed. 2d 772 (1997).
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Washington law made it criminal for any person to knowingly cause or aid another person to attempt suicide. The constitutionality of the statute was brought into question.
Synopsis of Rule of Law.
There is no fundamental right to a physician assisted suicide under the United States Constitution.
Facts.
Washington law makes it criminal for any person to knowingly cause or aid another person to attempt suicide. Exempted under the State law, however, is the withdrawal of life-sustaining treatment at a patient’s direction. The constitutionality of the statute was brought into question.
Issue.
Was Washington’s prohibition of causing or aiding a suicide in violation of the substantive due process component of the Fourteenth Amendment to the United States Constitution?
Held.
No.
The Due Process Clause of the Fourteenth Amendment protects those fundamental rights and liberties that are deeply-rooted in this Nation’s history and tradition and “implicit in the concept of ordered liberty such that neither liberty nor justice would exist if they were sacrificed.” In our Nation’s history, legal traditions, and practices, and in almost every state, it is a crime to assist a suicide. Therefore, a physician assisted suicide is not a fundamental right under our Constitution.
Since a physician assisted suicide is not a fundamental right, a state law prohibiting such suicide must be rationally related to a legitimate state interest.
The Court found the law here to be rationally related to a legitimate state interest. The state’s legitimate state interests here are numerous: (1) the preservation of human life; (2) the protection of the integrity and ethics of the medical profession; (3) the protection of vulnerable groups from abuse, neglect and mistakes, namely, subtle coercion an undue influence in end-of life situations, etc. The state’s prohibition on assisted suicide advances the state’s commitments to these interests.
Concurrence. Justice O’Connor: The risk that a dying patient’s request for assistance in ending his or her life might not truly be voluntary justifies the prohibitions on assisted suicide here.
Justice Stevens: Justice Stevens concurs that the statute is not invalid on its face. Such a holding does not, however, foreclose the possibility that some applications of the statute might be invalid. How particular cases involving the statute might be decided in the future will depend on the specific facts of the cases.
Justice Souter: The Petitioners, the State, has advanced several interests to justify the assisted suicide law as applied to physicians treating mentally ill patients. The measures the Petitioners put forward to guard against subtle coercion may not always be effective.
Justice Ginsburg: Justice Ginsberg concurs with the reasoning of Justice O’Connor’s concurrence.
Justice Breyer: Although Justice Breyer concurs in the judgment, he does not believe that the Supreme Court should decide whether the right to an assisted suicide is fundamental. If the legal circumstances were different, for example, were state law to prohibit palliative care such as drugs to avoid pain at the end of life, the issue would be different.
Discussion.
This case explains the Supreme Court’s “assisted suicide” jurisprudence. The right to a physician assisted suicide is not so much characterized by the concept of “self-sovereignty” as the persons opposing the State law, Respondents, here would assert. Rather, whether the right exists under particular legal circumstances depends on the extent of recognition of the right in our Nation’s history and traditions.
