Public Health Trust of Dade County v. Wons

Brief Fact Summary. Wons (Defendant), a Jehovah's Witness, refused to receive a blood transfusion while still conscious and competent.

Synopsis of Rule of Law. A competent adult has a lawful right to refuse, for religious reasons, a blood transfusion even though death may result without it.

Facts. Wons (Defendant) refused to have a blood transfusion due to her religious beliefs as a Jehovah's Witness.  She was competent to make the decision at the time when she refused.  While she was unconscious, the Public Health Trust of Dade County (Plaintiff) obtained a court order allowing the transfusion.  When she awoke, Defendant appealed the order.  The district court reversed the order, holding that the Defendant's rights of religion and privacy could not be overridden.

Issue. Does a competent adult have a lawful right to refuse, for religious reasons, a blood transfusion even though death may result without it?

Held. [Judge not stated in casebook excerpt.]  Yes.  A competent adult has a lawful right to refuse, for religious reasons, a blood transfusion even though death may result without it.  The constitutional guarantees of religious freedom and privacy are sacred.  Although it is important to the development of Won's (Defendant) two minor children to have the nurture and support of their mother, it is not enough to override her fundamental constitutional rights.  In this case, Defendant made an informed choice, based upon her religious beliefs, and rejected the transfusion.  Without a compelling state interest to show otherwise, she has a right to make the choice.  Affirmed.    

Discussion. A patient may not be prevented from participating in risky activities.  The logical difference between refusing a medical treatment and climbing Mount Everest is small when evaluating the risk to the patient's life.  Inconsistent intervention by the state cannot be easily tolerated when it tends to isolate specific groups on the basis of religious beliefs.
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