## Facts

- Vincent Lambert suffered severe brain injury in a 2008 traffic accident and remained in a chronic vegetative or minimally conscious state.
- His treating physician concluded Lambert’s condition was irreversible and, under French end-of-life law, initiated a collegial process to assess whether continued artificial nutrition and hydration (ANH) constituted “unreasonable obstinacy.”
- After consultation with the care team and family, the physician decided to withdraw ANH; administrative courts initially suspended that decision.
- A second collegial procedure again recommended withdrawal of ANH as disproportionate and without meaningful therapeutic benefit.
- France’s highest administrative court (Conseil d’État) obtained independent medical expert reports, heard the parties, and upheld the lawfulness of withdrawing ANH, including as a form of “treatment” that may be discontinued in specified circumstances.
- Lambert’s parents and two siblings applied to the European Court of Human Rights, alleging violations of the rights to life, freedom from inhuman treatment, and respect for private life.
- Interim measures required continuation of ANH during the proceedings; the case was decided by the Grand Chamber.

## Issues

1. Whether Lambert’s parents and siblings had standing to complain on Lambert’s behalf, and/or to complain in their own right as close relatives.
2. Whether authorizing withdrawal of ANH violated the State’s positive obligations to protect life under Article 2.
3. Whether the same facts disclosed separate violations of Articles 3 and 8.

## Decision

- The Court held the applicants lacked standing to act on Lambert’s behalf, finding no sufficient basis to treat their wishes as converging with Lambert’s own presumed wishes and no risk of ineffective protection of Lambert’s rights.
- The Court accepted that close relatives could raise an Article 2 complaint in their own right and examined the right-to-life claim on that basis.
- The Court found no violation of Article 2, concluding that the domestic legal framework and the decision-making process satisfied the State’s obligations.
- The Court found no separate violation of Articles 3 or 8 based on the applicants’ own rights, given the standing ruling and the Article 2 analysis.

## Legal Principles

- Article 2 imposes both negative duties not to take life intentionally and positive duties to take appropriate steps to safeguard life; end-of-life treatment withdrawal engages Article 2 where death will foreseeably follow.
- Withdrawal of life-sustaining measures may be distinguished from euthanasia or assisted suicide where the measure is characterized as medical treatment deemed futile or disproportionate and discontinued under law.
- In end-of-life matters, States have a margin of appreciation to regulate withdrawal of life-sustaining treatment and to balance protection of life with respect for private life and personal autonomy, subject to review for compliance with Article 2.
- Article 2 compliance in this setting turns heavily on procedural safeguards, including a clear and accessible legal framework, a structured collegial medical decision process, consultation with family, and meaningful judicial review.
- Domestic authorities must make serious efforts to ascertain the patient’s wishes (including through prior oral statements where no written directive exists) and to ensure decisions are not arbitrary.

## Conclusion

The Court held that France’s authorization of withdrawing artificial nutrition and hydration from a severely brain-injured patient did not breach the right to life where domestic law provided a clear basis for the decision and the case involved careful collegial medical assessment, consultation, and intensive judicial scrutiny aimed at preventing arbitrariness and identifying the patient’s presumed wishes.


Lambert v. France, App. No. 46043/14 (Eur. Ct. H.R. 2015)