By:- Rishi Saraf
|NAME OF THE CASE||Vacco v. Quill|
|CITATION||Vacco v. Quill, 521 U.S. 793 (1997)|
|DATE OF THE CASE||Argued – Jan 8, 1997 Decided: Jun 26, 1997|
|ADVOCATES||# Dennis C. Vacco Argued the cause for the petitioners, on behalf of the Petitioners # Laurence H. Tribe Argued the cause for the respondents # Walter E. Dellinger, IIIon behalf of the United States, as amicus curiae|
|BENCH/JUDGES||William Rehnquist, John P Stevens,Sandra Day O’Connor , Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, RuthBader Ginsburg, Stephen Breyer.|
|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?|
|STATUTES INVOLVED||“The Equal Protection Clause commands that no State shall “deny to any person within its jurisdiction the equal protection of the laws.” Under the Equal Protection Clause of the Fourteenth Amendment, a state statute forbidding assisted suicide was challenged as unconstitutional.|
VACCO vs. QUILL, This was a landmark decision that addressed the issue of patients’ right to die. The state of New York had enacted a prohibition on physicians assisting their patients in dying if they were terminally ill or in severe pain. The United States Supreme Court ruled that the prohibition did not violate a person’s freedom to refuse treatment. The analysis aims to scrutinize the background, facts, issues raised, and arguments on both sides and highlight concepts made in the case.
Death with dignity legislation, also known as physician-assisted suicide or aid-in-dying legislation is based on the idea that terminally ill people, not the govt and its interference, political leaders and their ideologies, or religious leaders and their dogma, should make end-of-life decisions and choose how much suffering and pain they should bear. Physician-assisted suicide, often known as “medical help in dying,” is permitted in eleven states in the United States: California, Colorado, the District of Columbia, Hawaii, Montana, Maine, New Jersey, New Mexico, Oregon, Vermont, and Washington.
In this case, the question is whether New York’s prohibition on physician-assisted suicide violates the Equal Protection Clause. In a nutshell, this ruling proved that there was no constitutional protection of a “right to die.”
FACTS OF THE CASE
Physician-assisted suicide was made illegal in New York, making it a crime for a doctor to give fatal medicines or otherwise intentionally and knowingly take a patient’s life, even if the patient was consenting, mentally competent, and terminally sick. A group of physicians then filed a lawsuit in the United States District Court for the Southern District of New York against New York’s Attorney General, contesting the Act on constitutional grounds.
They claimed that because New York (Defendant) enables a competent person to refuse life-sustaining medical care and such refusal is “basically the same thing” as physician-assisted suicide, Defendant’s restriction on assisted suicide violated the Fourteenth Amendment’s Equal Protection Clause, however the District Court ruled in favor of the New York statute.
It is worth noting that the United States Court of Appeals for the Second Circuit reversed the District Court’s judgment and agreed with the petitioner’s arguments, asserting that “New York law does not treat equally all competent persons who are in the final stages of fatal illness and wish to hasten their deaths,” then certiorari was granted by the highest court of the USA regarding this matter where the rest of the hearing was conducted. The Supreme Court heard oral arguments on January 8, 1997, from Attorney General Dennis C. Vacco for the petitioner, Laurence H. Tribe for the respondent, and General Walter Dellinger, Acting Solicitor General, as Amicus for the United States. Petitioners include a variety of New York governmental authorities. Timothy E. Quill, Samuel C. Klagsbrun, and Howard A. Grossman are New York-based physicians.
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?
ARGUMENTS OF THE PETITIONER
The petitioners said that there is a significant governmental interest in preserving human life, and that there is a clear distinction between the termination of life support and the active administration of a fatal medicine. As a result, the petitioners said, the prohibition on physician-assisted suicide does not violate Equal Protection.
ARGUMENTS BY THE RESPONDENT
The respondents reiterated their position that it was entirely within their rights as physicians to be free of prosecution for assisting their mentally competent patients during the final stages of terminal illness, even if it meant relieving a patient’s suffering through the prescription of lethal medication.
Respondents further contended that the prohibition on physician-assisted suicide violates Equal Protection because terminally ill people on life support are allowed to terminate their lives by withdrawing life support, but individuals who are not on life, support does not have the same option.
The Supreme Court overturned the Second Circuit’s Equal Protection ruling after reviewing the constitutional concerns raised in Vacco v. Quill. The Court ruled that New York’s laws forbidding assisted suicide did not deprive terminally ill patients or their doctor’s equal legal protection.
The Equal According to the Supreme Court, Protection Clause compels governments to treat identically those persons who are similarly situated. The Clause does not forbid legislative classifications 40, but it does require that they be supported by some governmental interest. If categorization is questionable or infringes on a basic right, the Court will carefully examine it to determine if it is required to accomplish a compelling state purpose. 41 If there is no questionable classification or basic right at stake, the Court will use a simple rationality test to establish whether the classification is logically connected to a valid state purpose.
The Court began its equal protection review of the New York legislation by noting that they did not “infringe basic rights or entail dubious classifications.” As a result, the legislation was subjected to the simple reasonableness test. The Court examined the New York legislation and determined that they did not establish a facial categorization. The laws did not “treat anyone differently than anybody else or make any differences between people. According to the Court, New York law allows all competent persons to decline life-saving medical care but forbids all persons from helping in a suicide. The legislation handled identically those persons who were similarly placed, and hence included no categorization at all on the surface.
The Court then examined the Second Circuit’s determination that, as applied, New York law authorized medical help in some, but not all, suicide instances. This finding was based on the concept that when a physician withholds or withdraws life-saving medical care from a patient who has opted to forego such care, he is committing “neither more nor less than assisted suicide.” The New York regulations violated the Equal Protection Clause, according to the Second Circuit, since no legitimate state interest could justify forbidding medical help in suicide for competent, terminally ill individuals who are not reliant on life-saving treatment.
The Court rejected the assumption that the “as-applied” equal protection claim was based on. The Court reasoned that eating a deadly amount of medications to cause death obviously contains the components of causation and purpose required for the conduct to be legally classified as suicide. Refusing life-saving medical care lacks these features and is hence not suicide. Because “when a patient declines life-sustaining medical care, he dies from an underlying fatal illness or pathology,” the Court found that the element of causation is missing. In both the patient and the physician, the element of intent is missing.
A patient who resists therapy is unlikely to be motivated by a desire to commit suicide. Rather, an individual’s denial or request for treatment termination is frequently motivated by a wish to live “free of undesired medical technology, surgery, or medicines”. A physician who follows a patient’s rejection or request for treatment discontinuation “simply intends, or may aim, to follow his patient’s preferences and ‘to discontinue doing pointless, pointless, or demeaning things to the patient when [the patient] no longer stands to profit from them.” The Court decided that there was a real distinction between eating a deadly amount of pharmaceuticals and refusing medical care based on causality and purpose.
According to the Court, the distinction was “significant and logical,” as well as “surely sensible.” “[I]n certain situations, the boundary between [stopping life-saving medical care and assisted suicide] may not be apparent, but certainty is not necessary, even if it were attainable,” the Court said shortly.
The Court got the closest to recognizing the plaintiffs’ allegation that denying life-saving medical care might occasionally be used to commit suicide. In rare cases, therapy may be rejected with the explicit and confessed goal of causing death. If the rejection of therapy causes a decrease in the health of someone who is normally anticipated to survive for a long time, the refusal appears to be suicide. The equal protection challenge to the New York legislation looked most convincing here. If denying treatment was a way of committing suicide, some New York patients received suicide help, while others were refused this choice.
The Court, on the other hand, affirmed its finding that the right to reject treatment existed and that it was logically separate from the alleged right to physician-assisted suicide. The Court stated that New York’s interests in “preventing intentional killing and preserving life; preventing suicide; maintaining physicians’ role as healers for their patients; protecting vulnerable people from indifference, prejudice, and psychological and financial pressure to end their lives; and avoiding the possible slide toward euthanasia… [are] valid and important public interests.”
The Court concurred with the implied findings of the New York legislature that the ban of assisted suicide advances these state interests and is not impeded by the concurrent acknowledgement of a right to decline life-saving medical care. The Court unanimously decided that New York’s restriction on assisted suicide does not violate the Fourteenth Amendment’s Equal Protection Clause.
State laws that do not involve a suspect classification or infringe on a fundamental right are given a “strong presumption of validity” under the mere rationality standard. Given this strong presumption, the Court could have upheld the challenged New York statutes without asserting an actual distinction between aiding in the termination of medical treatment and providing the means for one to do so. If the Court believed that “the principal duty of the State [is] to maintain and promote liberty and personal autonomy of the individual,” a difference between the two types of conduct based on cause and purpose would be unnecessary or irrelevant.
Prohibitions on physician-assisted suicide with a strong presumption of validity might satisfy the simple reasonableness test as possibly essential to guard against infringements on human liberty that would accompany the legalization of physician-assisted suicide. However, in its equal protection reasoning, the Court emphasized the significance and inherent logic of the distinction between withholding life-saving medical care and assisting suicide. It also recognized the legality of the state’s interest in protecting life and prohibiting deliberate killing, both of which restrict human autonomy. In these two critical areas, the Court’s interpretation is consistent with the concept that ensuring the inherent right to life is a legitimate role of civil government.
- Vacco v. Quill, 521 U.S. 793 (1997)
- Arestad, Kim C. (1999) “VACCO V. QUILL AND THE DEBATE OVER PHYSICIAN-ASSISTED SUICIDE: IS THE RIGHT TO DIE PROTECTED BY THE FOURTEENTH AMENDMENT?,” NYLS Journal of Human Rights: Vol. 15 : Iss.3, Article 5. Available at: https://digitalcommons.nyls.edu/journal_of_human_rights/vol15/iss3/5
- Vacco v. Quill, 521 U.S. 793, 117 S. Ct. 2293, 138 L. Ed. 2d 834, 1997 U.S. LEXIS 4038, 65 U.S.L.W. 4695, 97 Cal. Daily Op. Service 5027, 97 Daily Journal DAR 8122, 11 Fla. L. Weekly Fed. S 174