## Facts

- Karen Ann Quinlan, a young adult, suffered respiratory arrest and anoxic brain injury and remained in a persistent vegetative state.
- She was maintained at a hospital on a mechanical respirator and other life-sustaining measures.
- Her father petitioned for a declaration of her incompetency, appointment as guardian, and authority to discontinue “extraordinary” medical procedures said to offer no reasonable hope of recovery.
- The hospital and treating physicians refused to remove the respirator, citing medical ethics and concern about criminal and civil liability.
- The State and county prosecutor opposed withdrawal, asserting a strong state interest in preservation of life and concerns that removal could constitute homicide or euthanasia.
- The trial court found Karen incompetent but denied authority to terminate the respirator and limited guardianship over her person; the father appealed.

## Issues

1. Whether an incompetent patient has a constitutionally protected interest, exercisable through a guardian, to refuse extraordinary life-sustaining treatment when there is no reasonable possibility of regaining cognitive function.
2. Whether a parent may be appointed guardian of the person with authority to consent to withdrawal of extraordinary life support on the patient’s behalf.
3. How the patient’s rights should be balanced against the State’s interests in preserving life and preventing homicide or suicide, and whether compliant withdrawal exposes participants to civil or criminal liability.

## Decision

- The Supreme Court of New Jersey modified the judgment and remanded.
- The court held that the patient’s constitutional right of privacy included the choice to decline extraordinary life-sustaining treatment in a permanent noncognitive state, and that this right could be asserted through substituted judgment by her guardian with family support.
- The court directed appointment of the father as guardian of the person, with authority to consent to withdrawal of life-support systems if specified safeguards were met.
- The court required: (1) concurrence of guardian and family; (2) attending physicians’ determination that there was no reasonable possibility of return to a “cognitive, sapient state” and that life support should be discontinued; and (3) concurrence of the hospital ethics committee.
- If those conditions were satisfied, withdrawal would be permitted and would carry no civil or criminal liability for the guardian, physicians, or hospital.

## Legal Principles

- A constitutional privacy interest protects bodily autonomy and may include refusal of extraordinary medical treatment that only prolongs biological existence without cognitive function.
- For an incompetent patient, substituted judgment may be exercised by a properly appointed guardian, informed by the family and evidence of the patient’s likely wishes.
- The State’s interest in preserving life is not absolute and may diminish as prognosis becomes hopeless and the degree of bodily intrusion from treatment increases.
- Withdrawal of extraordinary life support, under defined medical and institutional review procedures, is treated as allowing death from natural causes rather than as affirmative killing.
- Courts may authorize a structured process (medical prognosis plus ethics committee review) both to protect the patient’s interests and to clarify that compliant conduct avoids civil and criminal liability.

## Conclusion

The court recognized a privacy-based right, exercisable through a guardian, to discontinue extraordinary life-sustaining treatment for an incompetent patient in a persistent vegetative state, and established medical and ethics-committee safeguards that permit withdrawal without civil or criminal liability.


In re Quinlan, 70 N.J. 10, 355 A.2d 647 (N.J. 1976)