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Vacco v. Quill

This 1997 U.S. Supreme Court ruling reversed a Second Circuit ruling, upholding New York State’s ban on assisted suicide, holding that the terminally ill do not have a right to physician-assisted suicide under the Equal Protection Clause of the U.S. Constitution. Rehnquist, in his ruling opinion, reaffirmed that the equal protection clause creates no substantive rights. "Instead, it embodies a general rule that States must treat like cases alike but may treat unlike cases accordingly." The ruling held that New York's prohibition does not treat those terminally ill who are seeking assisted suicide differently from those terminally ill who could hasten death by ending life-sustaining treatment. The court maintained that all competent persons have a right to refuse treatments, but this is not the same as suicide--a distinction long recognized by both the medical and legal professions. In other words, it has long been recognized that people have a right to refuse unwanted treatments, but this is not tantamount to self-killing. [Source: Vacco v. Quill, 117 S.Ct. 2293 (1997).]

In her concurring opinion on Vacco v. Quill and Washington v. Glucksberg, Justice O’Connor confirmed that individual States might choose to permit physician assisted suicide, not as a Constitutionally-protected right, but as a "carefully struck balance" between an individual’s liberty interest and the States’ interest in preserving and protecting life:

    Every one of us at some point may be affected by our own or a family member’s terminal illness. There is no reason to think the democratic process will not strike the proper balance between the interests of terminally ill, mentally competent individuals who would seek to end their suffering and the State's interests in protecting those who might seek to end life mistakenly or under pressure. As the Court recognizes, States are presently undertaking extensive and serious evaluation of physician assisted suicide and other related issues. Ante, at 11, 12-13; see post, at 36-39 (Souter, J., concurring in judgment). In such circumstances, "the . . . challenging task of crafting appropriate procedures for safeguarding . . . liberty interests is entrusted to the `laboratory' of the States . . . in the first instance." Cruzan v. Director, Mo. Dept. of Health, 497 U.S. 261, 292 (1990) (O’Connor, J., concurring) (citing New State Ice Co. v. Liebmann, 285 U.S. 262, 311 (1932)).

Principles & Concepts: human dignity, respect for persons, autonomy, informed consent, right to die.

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