Vacco v. Quill

Following is the case brief for Vacco v. Quill, 521 U.S. 793 (1997)

Case Summary of Vacco v. Quill:

  • New York makes it a crime to assist someone with suicide.  However, it is legal for a patient to refuse life-saving treatment.
  • New York doctors and several terminally ill patients sued in federal court, claiming that the ban on physician-assisted suicide violates the Equal Protection Clause.
  • The District Court dismissed the case, but the Second Circuit reversed, finding no difference between those refusing life-saving treatment, which is legal; and those who wish to take medication to end their lives, which is illegal.
  • The U.S. Supreme Court reversed the Second Circuit.  It held that there is no equal protection problem because there is a difference between letting someone die, and making someone die.

Vacco v. Quill Case Brief

Statement of the Facts:

New York, like many States, makes it a crime to help another commit or attempt suicide.  However, New York law allows patients to refuse life-saving treatment.  Respondents in this case – New York physicians, terminally ill patients who are suffering great pain and wish to end their lives, and three patients who died before the case made it to the Supreme Court – claim that New York’s ban on physician-assisted suicide violates the Equal Protection Clause of the Fourteenth Amendment.  They assert that there is no legitimate state interest that justifies treating differently those patients who wish to hasten their deaths with prescribed drugs from those patients who hasten their deaths by removing life-support systems.

Procedural History:

  • The District Court dismissed Respondents’ claim.
  • The Second Circuit Court of Appeals, however, reversed finding an equal protection violation.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Does New York’s ban on physician-assisted suicide violate the Equal Protection Clause?  No.

Judgment:

The decision of the Second Circuit Court of Appeals is reversed.

Rule of Law or Legal Principle Applied:

The difference between letting a patient die by removing life-saving treatment, and making a patient die with prescribed drugs is a distinction that justifies different treatment.

Reasoning:

The Equal Protection Clause generally means that similar cases are to be treated similarly.  However, there is a large distinction between letting someone die by removing life-saving treatment, and making someone die with the intentional prescription of life-ending medication.  Thus, the Court disagrees with the Second Circuit’s assertion that refusing life-saving treatment is “nothing more nor less than assisted suicide.”  The difference is causation.  Death occurs in one instance because of natural causes, whereas in the other instance death occurs because of the physician-prescribed drugs.  Therefore, there is no equal protection problem because the cases are different.  Moreover, New York’s interest in banning physician-assisted suicide includes the desire to prevent intentional killing and preserve life, keep physicians as healers, and protecting vulnerable people.

Concurring and Dissenting Opinions:

Concurring Opinion (O’Connor) (from concurring opinion in Washington v. Glucksberg):

The respondents in this case do not urge a general right to “commit suicide.”  Rather, they seek an answer to the narrower question as to whether a mentally competent person, who is experiencing immense suffering, has a constitutionally recognizable interest in controlling the circumstances of his or her imminent death.  In the context of this case, there is no reason to reach that question.

Concurring Opinion (Stevens) (from concurring opinion in Washington v. Glucksberg):

While the Court’s holding is consistent with allowing a vigorous debate on the assisted-suicide issue to continue, it should be noted that there is also room for debate on the constitutional limits on a State to punish the practice of assisted suicide.

Concurring Opinion (Souter):

Assisted suicide is not a fundamental right, but the claims here deserve a high degree of importance.

Concurring Opinion (Ginsburg) (from concurring opinion in Washington v. Glucksberg):

Justice Ginsburg concurs for the reasons stated in Justice O’Connor’s concurring opinion.

Concurring Opinion (Breyer) (from concurring opinion in Washington v. Glucksberg):

Justice O’Connor’s opinion has more significance than the Court’s opinion may suggest.  In a different case, in which a patient seeks to avoid pain at the end of life, the Court would likely have to revisit its conclusions.

Significance:

Vacco v. Quill is the companion case with Washington v. Glucksberg, and presents the current state of affairs regarding physician-assisted suicide.  The interesting element in this case is the equal protection argument, exploring the difference between someone who chooses to refuse life-saving treatment and someone who chooses medication to expedite death.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

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