Under the Equal Protection Clause of the Fourteenth Amendment, a state statute forbidding assisted suicide was challenged as unconstitutional.
Facts of the case
Dr. Timothy E. Quill, along with other physicians and three seriously ill patients who have since died, challenged the constitutionality of the New York State’s ban on physician-assisted suicide. New York’s ban, while permitting patients to refuse lifesaving treatment on their own, has historically made it a crime for doctors to help patients commit or attempt suicide, even if patients are terminally ill or in great pain. Following a District Court ruling favoring the State of New York, the Second Circuit reversed and the Supreme Court granted New York certiorari.
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?
Although there is a distinction between refusing lifesaving medical treatment and assisted suicide, neither violates the Equal Protection Clause since they apply evenhandedly to all.Â
Logic and current practice support New York’s (Defendant) judgment that the two acts are different and, therefore, Defendant may treat them differently, consistent with the Constitution.Â
A doctor who assists a suicide must, necessarily and unquestionably, primarily intend that the patient be made dead.Â
The law has long used actors’ intent or purpose to distinguish between two acts that may have the same result.Â
The overwhelming majority of state legislatures have drawn a clear line between assisted suicide and withdrawing or permitting the refusal of unwanted lifesaving medical treatment by prohibiting the former but allowing the latter.Â
New York’s (Defendant) statutes outlawing assisted suicide do not infringe fundamental rights or involve suspect classifications, and therefore are entitled to a strong presumption of validity.Â
On their faces, neither Defendant’s ban on assisted suicide nor its statutes that allow patients to refuse medical treatment treat anyone differently or draw any distinctions between individuals.Â
Generally speaking, laws that apply evenhandedly to all unquestionably comply with the Equal Protection Clause.Â
“The New York criminal statutes did not violate the equal protection clause, because (1) the criminal statutes neither infringed fundamental rights nor involved suspect classifications
(2) on their faces, neither the statutes banning assisted suicide nor the statutes permitting the refusal of medical treatment treated anyone differently than anyone else or drew any distinctions between persons
(3) the distinction between assisting suicide and refusing lifesaving medical treatment was important, logical, and rational
and (4) New York’s reasons for recognizing and acting on the distinction between assisting suicide and refusing lifesaving medical treatment were valid and important public interests. Thus, it was entitled to a strong presumption of validity.”
Case Brief: 1997
Decided by: Rehnquist Court
Citation: 521 US 793 (1997) Argued: Jan 8, 1997 Decided: Jun 26, 1997