## Facts

- A 25-year-old patient was admitted to a hospital with a ruptured duodenal ulcer, massive blood loss, and imminent risk of death absent transfusion.
- The patient and her husband were Jehovah’s Witnesses and refused consent to blood transfusions on religious grounds.
- The husband maintained his refusal but indicated he would accept a court order as removing personal responsibility for the decision.
- A physician reported that, when told a court might order transfusion, the patient conveyed that if a court ordered it, it would not be her responsibility.
- The hospital sought judicial authorization to administer transfusions immediately and to clarify the hospital’s and physicians’ exposure to liability if they either treated or withheld treatment.
- A federal district judge denied the request; the hospital sought emergency relief from a circuit judge in chambers.
- The circuit judge issued an emergency order authorizing transfusions limited to what was necessary to save the patient’s life.

## Issues

1. Whether a court may authorize a hospital to administer life-saving transfusions to an adult who objects on religious grounds when her ability to make a competent decision is impaired by a medical emergency.
2. Whether the need to clarify a hospital’s and physicians’ potential civil or criminal liability can justify emergency equitable relief authorizing treatment.
3. How the free exercise of religion affects judicial power to permit treatment in an emergency involving threatened loss of life.

## Decision

- The court granted emergency relief and authorized the hospital to administer blood transfusions to the extent necessary to save the patient’s life.
- The court treated the matter as an equitable request akin to injunctive and declaratory relief to determine rights and obligations in an urgent setting.
- The court relied heavily on the patient’s critical condition and compromised decisional capacity, emphasizing the limited, emergency character of the authorization.
- The court concluded that religious objections were not controlling in these circumstances, particularly where the patient’s competence was impaired and death would otherwise likely occur before judicial review.
- The order was framed as necessary to prevent the controversy from becoming moot through the patient’s death and to protect physicians while acting under court authorization.

## Legal Principles

- Courts may issue emergency equitable orders authorizing treatment when immediate action is required to preserve life and to preserve the court’s ability to adjudicate the dispute.
- A refusal of treatment is less determinative when the patient’s capacity for a competent, voluntary decision is materially compromised by critical illness.
- Free exercise rights are not absolute in medical emergencies; religious objections may yield where the state’s interest in preserving life is immediate and the patient is not fully competent.
- In deciding whether to authorize treatment, a court may consider the hospital’s and physicians’ exposure to liability and the need for clear legal authorization in time-sensitive conditions.
- The scope of relief may be confined to the minimum necessary intervention (here, transfusions only as needed to save life).

## Conclusion

The court authorized emergency transfusions for a critically ill Jehovah’s Witness, reasoning that the patient’s decisional capacity was impaired, death was imminent, and limited equitable relief was necessary to preserve life and to provide legal protection for clinicians acting under judicial authorization.


Application of the President & Dirs. of Georgetown Coll., Inc., 331 F.2d 1000 (D.C. Cir. 1964)