## Facts

- Cassandra C., age 17, was diagnosed with Hodgkin’s lymphoma, for which medical testimony indicated a high likelihood of cure with chemotherapy and a high likelihood of death without treatment.
- Cassandra, supported by her mother, refused chemotherapy due to anticipated side effects, preference for alternative remedies, and willingness to accept the risk of death.
- Health providers reported the refusal to the Department of Children and Families (DCF), which sought an order of temporary custody and a finding that Cassandra was “uncared for” due to lack of necessary medical care.
- The juvenile court granted temporary custody to DCF, found Cassandra “uncared for,” and authorized DCF to consent to and require chemotherapy over Cassandra’s objection.
- Cassandra initially complied, then ran away to avoid treatment; she was located, returned to DCF custody, and chemotherapy resumed.
- Cassandra appealed, arguing she was sufficiently mature to refuse life-saving care and urging recognition of a “mature minor” doctrine.

## Issues

1. Whether Connecticut should recognize a “mature minor” doctrine permitting a sufficiently mature minor to refuse life-saving medical treatment.
2. Whether the juvenile court clearly erred in finding Cassandra was not sufficiently mature to make an informed, independent refusal of chemotherapy.
3. Whether compelled chemotherapy for a nearly 18-year-old minor violates constitutional protections for bodily integrity and decisional autonomy.

## Decision

- The Connecticut Supreme Court affirmed the juvenile court’s orders authorizing DCF custody and medical decision-making, including chemotherapy over Cassandra’s objection.
- The court did not adopt a broad mature minor doctrine conferring adult-equivalent medical refusal rights on minors.
- Assuming arguendo that a maturity-based inquiry could be relevant, the court held the record supported the juvenile court’s determination that Cassandra was not a mature minor under any such standard.
- The court upheld the “uncared for” finding and concluded compelled treatment did not violate Cassandra’s constitutional claims in these circumstances.

## Legal Principles

- The state may act under parens patriae to protect a minor’s life and health when refusal of medically necessary treatment creates a serious risk of grave harm or death.
- Minors’ medical decision-making autonomy is generally more limited than that of competent adults; parental authority is also limited when parental choices place a child at substantial risk.
- If a maturity assessment is considered, it is fact-specific and may include the minor’s understanding of the condition and treatment, appreciation of consequences, stability and independence of the choice, and susceptibility to external influence.
- Appellate review of trial-court findings on a minor’s maturity is deferential; such findings will be upheld absent clear error.
- A minor’s asserted bodily integrity and due process interests may yield to the state’s compelling interest in preserving the life of a child where the child has not been found sufficiently mature to refuse life-saving treatment.

## Conclusion

The court upheld state intervention and compelled chemotherapy for a 17-year-old who refused highly effective, life-saving treatment, concluding that Connecticut law did not require recognition of an adult-like right of medical refusal for minors and that the trial court’s finding of immaturity supported DCF’s authority to consent to treatment.


In re Cassandra C., 112 A.3d 158 (Conn. 2015)