Vacco v. Quill

The Facts

Physicians assert it would be “consistent with the standards of their medical practices to prescribe lethal medication for mentally competent, terminally ill patients who are suffering great pains and desire a doctor’s help in taking their own lives.”  New York’s state law outlaws them from doing so, which is the basis of this action.  New York law currently allows patients the right to refuse life saving treatment.  The physicians argue that permitting physician assisted suicide would essentially be the same thing.

Rule

Equal Protection Clause:  “no State shall deny to any person within its jurisdiction the equal protection of laws.”

“The law has long used actors’ intent or purpose to distinguish between two acts that may have the same result. Put differently, the law distinguishes actions taken because of a given end from actions taken in spite of their unintended but foreseen consequences.”

The Issue

“Whether New York’s prohibition on assisting suicide therefore violates the Equal Protection Clause of the 14th Amendment.”

The Holding

No, court of appeals decision reversed. The distinction between a patient’s refusal of life saving treatment and assisting suicide is “both important and logical; it is certainly rational.”  The distinction is rooted in principles of causation and intent.  When a patient refuses treatment, he dies directly by way of the ailment causing death.  When the physician assists in suicide he dies directly from the physician’s actions.  “A patient who commits suicide with a doctor’s aid necessarily has the specific intent to end his or her own life, while a patient who refuses or discontinues treatment might not.”  Nearly all state legislatures have drawn a line in the sand similar the one reached in New York.  Moreover, the court has already drawn a distinction between “letting someone die” and “causing death.”  The right of the patient to left alone or refuse medical treatment is rooted in “traditional rights to bodily integrity and freedom from unwanted touching.”  Other reasons for the separation of these concepts include “prohibiting intentional killing and preserving life; preventing suicide; maintaining a physician’s role as their patient’s healers; protecting vulnerable people from indifference prejudice, and psychological and financial pressure to end their lives; and avoiding possible slide towards euthanasia.”

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