Vacco v. Quill

Brief Fact Summary. Under the Equal Protection Clause of the Fourteenth Amendment, a state statute forbidding assisted suicide was challenged as unconstitutional.

Synopsis of Rule of Law. Although there is a distinction between refusing lifesaving medical treatment and assisted suicide, neither violates the Equal Protection Clause since they apply evenhandedly to all.

Facts. Quill (Plaintiff) and three gravely ill patients who have since died sued the New York State Attorney General (Defendant).  They urged that because New York (Defendant) permits a competent person to refuse life-sustaining medical treatment, and the refusal of such treatment is “essentially the same thing” as physician-assisted suicide, Defendant’s ban on assisted suicide was a violation of the Equal Protection Clause of the Fourteenth Amendment.  The district court disagreed, but the court of appeals for the Second Circuit reversed, finding that those in the final stages of fatal illness who were on life-support systems were allowed to hasten their deaths by choosing to have those systems removed; but those who were in a similar situation, except for the previous attachment of life-sustaining equipment, were not allowed to hasten death by self-administering drugs prescribed by a doctor.  The court of appeals concluded that this supposed unequal treatment was not rationally related to any legitimate state interest.  Certiorari was granted by the Supreme Court.

Issue. Although there is a distinction between refusing lifesaving medical treatment and assisted suicide, does this distinction operate in violation of the Equal Protection Clause by treating individuals who wish to end their lives differently?

Held. (Rehnquist, C.J.)  No.  Although there is a distinction between refusing lifesaving medical treatment and assisted suicide, neither violates the Equal Protection Clause since they apply evenhandedly to all.  Logic and current practice support New York’s (Defendant) judgment that the two acts are different and, therefore, Defendant may treat them differently, consistent with the Constitution.  A doctor who assists a suicide must, necessarily and unquestionably, primarily intend that the patient be made dead.  The law has long used actors’ intent or purpose to distinguish between two acts that may have the same result.  The overwhelming majority of state legislatures have drawn a clear line between assisted suicide and withdrawing or permitting the refusal of unwanted lifesaving medical treatment by prohibiting the former but allowing the latter.  New York’s (Defendant) statutes outlawing assisted suicide do not infringe fundamental rights or involve suspect classifications, and therefore are entitled to a strong presumption of validity.  On their faces, neither Defendant’s ban on assisted suicide nor its statutes that allow patients to refuse medical treatment treat anyone differently or draw any distinctions between individuals.  Generally speaking, laws that apply evenhandedly to all unquestionably comply with the Equal Protection Clause.  Reversed.

Concurrence. (Souter, J.)  The reasons that lead me to conclude that the prohibition on assisted suicide in Glucksberg is not arbitrary under the due process standard also support the distinction between assisted suicide, which is banned, and practices such as termination of artificial life support and pain medication that hastens death, which are permitted.

Discussion. Assisted suicide and euthanasia are officially prohibited, but doctors are not criminally prosecuted for either.  Juries do not usually convict physicians who assist in their patients’ suicides.