## Facts

- E.G., a 17-year-old Jehovah’s Witness, was diagnosed with acute nonlymphatic leukemia.
- Physicians advised that treatment required blood transfusions.
- E.G. refused transfusions on religious grounds and asserted the decision as her own.
- E.G.’s mother, Rosie Denton, also refused to consent to transfusions but authorized other treatment and executed a liability waiver regarding transfusions.
- The State initiated juvenile proceedings alleging medical neglect based on the refusal of transfusions.
- Evidence showed E.G. was highly mature, understood her condition and the role of transfusions, and appreciated that refusal substantially increased the risk of death.

## Issues

1. Whether a sufficiently mature 17-year-old may refuse life-saving medical treatment, including blood transfusions, based on personal and religious convictions.
2. How the State’s interests in preserving life, protecting minors, and preventing suicide weigh against a mature minor’s interest in bodily integrity and informed medical decision-making.
3. Whether a parent commits medical neglect by agreeing with a mature minor’s independent refusal of life-saving treatment.

## Decision

- The Illinois Supreme Court held that a sufficiently mature minor may have capacity to consent to or refuse medical treatment, to be determined case by case.
- The court accepted the lower courts’ factual findings that E.G. was mature and that her refusal was informed and voluntary; accordingly, she had the right to refuse transfusions.
- The court grounded the right primarily in common-law bodily self-determination rather than solely in free-exercise doctrine.
- The court reversed the neglect determination against E.G.’s mother and remanded with directions to expunge the neglect finding.

## Legal Principles

- Competent persons have a common-law right to bodily self-determination that includes refusing unwanted medical treatment.
- A “mature minor” may possess decision-making capacity comparable to an adult for medical choices when the minor demonstrates sufficient maturity and understanding.
- Maturity is a fact-specific determination considering age, intelligence, experience, and ability to understand the nature, risks, benefits, and consequences of the proposed treatment and refusal.
- The State’s interests in preserving life and protecting minors do not automatically override a mature minor’s informed refusal of treatment; they must be weighed in context.
- When a mature minor independently refuses treatment with capacity, a parent’s concurrence in that refusal, without more, is not medical neglect.

## Conclusion

Illinois recognized a limited mature minor doctrine allowing a sufficiently mature adolescent to refuse even life-saving treatment, and it held that neglect proceedings cannot be sustained against a parent solely for honoring the mature minor’s informed refusal.


In re E.G., 549 N.E.2d 322 (Ill. 1990)