Vacco V. Quill - Supreme Court Decision

Supreme Court Decision

On June 26, 1997, the Supreme Court issued a unanimous (9-0) decision. The majority opinion was authored by Chief Justice Rehnquist, and was joined by Justices Kennedy, Scalia, O'Connor, and Thomas. Justice O'Connor wrote a concurring opinion, joined in part by Justices Ginsburg and Breyer. Justices Stevens, Souter, Ginsburg, and Breyer filed separate concurring opinions. Interestingly, this means that even with majority support for one opinion, there were still six opinions total that were finally submitted.

The Court began its opinion by stating that the New York law did not infringe upon a fundamental right. In this line of reasoning, the Court referenced San Antonio School District v. Rodriguez 411 U.S. 1 (1973) which said, in relevant part, that the judiciary must look to the Constitution, rather than to the stated "importance" of a right, when determining whether that right was, indeed, fundamental. Because New York's ban did not infringe upon a fundamental right, and because respondents were not claiming that the "right to die" was fundamental, the Court reiterated its policy of according such laws a great deal of leeway. In the Court's own words, from Heller v. Doe, 509 U.S. 312 (1993) laws such as those enacted by New York were entitled to a "strong presumption of validity."

After addressing the matter of fundamental rights, the Court delineated the rationale behind its decision. It first turned to the long-standing legal tradition of looking to a person's intent as a way of distinguishing between two acts with identical physical consequences. For example, a person who accidentally kills a pedestrian while blinded by the sun might only face punishment for vehicular manslaughter, while a person who intentionally and purposefully kills another with his car could be punished for murder. While these two acts give the same results, they are distinguished by the intent of the actors.

The Court applied the standard of intent to the matter at hand, finding that a doctor who withdraws life support at the request of his patient intends only to respect his patient's wishes. This, the Court said, is a sharp contrast to the doctor who honors a patient's request to end their life, which necessarily requires more than an intent to respect their wishes; namely, it requires the intent to kill the patient. A major difference, the Court determined, in the two scenarios is that the former may cause the patient to die from underlying causes, while the latter will cause the patient to die by the hands of the physician. To this effect the Court quoted a House Judiciary Committee hearing, stating that a physician performing an assisted suicide, "must, necessarily and indubitably, intend primarily that the patient be made dead." Furthermore, in another repudiation of the respondents' argument, the Court noted that a patient removing life support might not actually intend to die, and that death without such a device may not be a certainty.

Looking to New York's intent behind the ban, the Court noted that the law plainly recognized the difference between "killing" and "letting die." It also recognized that the State of New York had, as a matter of policy, a compelling interest in forbidding assisted suicide, while allowing a patient to refuse life support was simply an act of protecting a common-law right. This right was not, contrary to the Court of Appeals' view, the "right to hasten death"; rather, the Court declared that it was the right to retain bodily integrity and to preserve individual autonomy. The prevention of "unwanted touching" was, the Court said, a very legitimate right to protect.

In closing, the Court said that it fully rejected the respondents' argument that the statutory difference between assisted suicide and refusing lifesaving treatment was "arbitrary" and "irrational." It did concede that there were probably incidents where the two were likely to have the same result, but also said that such an argument was beside the point. The Court declared that New York "obviously" had a number of legitimate, compelling, and rational interests in enacting this ban. However, regardless of these reasons, it determined simply that the law permitted everyone to refuse treatment and prohibited everyone from assisting suicide; as such, the law did not run afoul of the Equal Protection Clause and the state had the constitutional authority to put such a law into place.