On April 15, 1975, twenty-one-year-old Karen Ann Quinlan of Landing, New Jersey, went out with friends. During the course of the evening, Quinlan consumed a mix of alcohol and prescription and over-the-counter drugs. Later that night, Quinlan lost consciousness and slipped into a coma. After doctors established that Quinlan would remain in a persistent vegetative state, her parents asked her doctors to remove her respirator, arguing that Quinlan’s life was being artificially sustained by extraordinary means. The doctors refused.
Quinlan’s parents, Joseph and Julia, then petitioned the New Jersey Superior Court to appoint Joseph as his daughter’s legal guardian. On November 10, 1975, Judge Robert Muir, Jr. refused, ruling that the court could not authorize the withdrawal of lifesustaining techniques under its equity jurisdiction or the constitutional rights of free exercise of religion, right to privacy, or privilege against cruel and unusual punishment.
The Quinlans appealed the decision to the New Jersey Supreme Court. On March 31, 1976, the supreme court held that under the Constitution’s right to privacy, Quinlan’s legal guardian and family could exercise Quinlan’s right to privacy on her behalf. The Quinlans removed the respirator on May 22, 1976. Quinlan lived for nine more years; on June 11, 1985, she succumbed to pneumonia. She was thirty-one years old.
Although not binding in other states, the decision in In The Matter of Karen Quinlan was a landmark case for the rights of patients to control their medical decisions and treatment. Following the decision, many states passed patients’ rights statutes that included provisions for living wills, thus allowing individuals the right to decide in advance what medical procedures would be permitted if they became incompetent.
MARY K. MANKUS
References and Further Reading
See also Cruzan v. Missouri, 497 U.S. 261 (1990)