## Facts

- Karen Ann Quinlan, age 21, suffered respiratory arrest episodes in April 1975 and sustained severe brain injury.
- She was treated at multiple hospitals and remained in a chronic comatose/vegetative state, dependent on a mechanical ventilator and other life-support measures.
- Medical testimony described an extremely poor prognosis, but physicians could not certify absolute irreversibility or that death was imminent if the ventilator were removed.
- Karen was not legally or medically dead under recognized standards.
- Her parents initially requested full treatment efforts; later, concluding there was no meaningful improvement, they sought withdrawal of “extraordinary” measures to allow death to occur naturally.
- The family reported Karen had previously stated she would not want to be kept alive by artificial or extraordinary medical procedures; the court viewed these remarks as generalized and not tied to a specific medical decision.
- Joseph Quinlan petitioned for appointment as guardian of Karen’s person and property and sought express authority to discontinue extraordinary life support, plus injunctive and declaratory relief to prevent interference by the hospital, physicians, and prosecutor and to preclude homicide prosecution.
- The Attorney General intervened for the State; a guardian ad litem was appointed for Karen.

## Issues

1. Whether Karen Quinlan was mentally incompetent such that a guardian should be appointed, and whether Joseph Quinlan was a suitable guardian.
2. Whether a court may grant a guardian express authority to discontinue mechanical ventilation and other extraordinary life-support for an incompetent adult who is not legally dead.
3. Whether the court may restrain prosecutorial action or otherwise declare that withdrawal of life support would not subject participants to homicide liability.
4. Whether prior statements and asserted constitutional/common-law interests supported vicarious refusal of life-sustaining treatment in these circumstances.

## Decision

- The court adjudicated Karen Quinlan mentally incompetent.
- The court appointed Joseph Quinlan as guardian of her person and property.
- The court denied the request to include in the guardianship authority the express power to discontinue the ventilator and other extraordinary life-support measures.
- The court denied injunctive and declaratory relief aimed at preventing interference by the prosecutor, hospital, or physicians and refused to immunize participants from potential criminal prosecution.

## Legal Principles

- Guardianship may be granted for an adult who is medically alive but unable to make informed decisions due to profound incapacity.
- A chancery court will not, absent clear legal authority and standards, pre-approve withdrawal of life-sustaining mechanical ventilation when death would foreseeably follow and the act could be characterized as causally linked to death under criminal law.
- General, non-specific prior statements about not wanting “artificial” life support may be insufficient to constitute an informed, binding refusal of a particular life-sustaining intervention in a specific clinical setting.
- Courts may decline to issue broad prospective relief restraining prosecutors or declaring non-liability where such relief would function as advance immunity from potential homicide charges.

## Conclusion

The Chancery Division appointed Karen Quinlan’s father as guardian based on her incompetency but refused to authorize termination of mechanical ventilation or to bar potential criminal enforcement, concluding that existing law and medical standards did not clearly permit judicial approval of withdrawing life support in these circumstances.


In re Quinlan, 348 A.2d 801 (N.J. Super. Ct. Ch. Div. 1975)