Facts
- Norma Wons, a competent adult and practicing Jehovah’s Witness, was admitted to Jackson Memorial Hospital for dysfunctional uterine bleeding.
- Treating physicians advised that without a blood transfusion she would, in all probability, die.
- While conscious and able to make an informed decision, Wons expressly refused a transfusion because her religious beliefs prohibited receiving blood from outside her body.
- The Public Health Trust of Dade County (hospital operator) petitioned a circuit court for authority to administer a transfusion over Wons’s objection.
- The trial court authorized the transfusion, reasoning that Wons’s minor children had a right to be reared by two loving parents that outweighed her religious freedom and privacy rights.
- The transfusion was administered while Wons was unconscious.
- The Third District Court of Appeal reversed, and certified to the Florida Supreme Court whether a competent adult may lawfully refuse a blood transfusion even though death may result.
Issues
- Whether a competent adult has a lawful right, grounded in constitutional privacy and religious freedom, to refuse a blood transfusion even if death is likely.
- Whether the state’s interests in preserving life and protecting minor children were sufficiently compelling, on these facts, to justify overriding the patient’s refusal.
Decision
- The Florida Supreme Court approved the Third District’s decision and answered the certified question yes.
- The court held that a competent adult’s informed refusal of a blood transfusion on religious grounds must be honored absent a sufficiently compelling state interest.
- The state’s asserted interests, including preserving life and protecting Wons’s minor children, did not justify compelled treatment on the record presented.
- The trial court’s order authorizing the transfusion over Wons’s objection was therefore improper.
Legal Principles
- A competent adult’s informed medical decisions, including refusal of treatment, fall within the Florida Constitution’s right of privacy.
- Refusal of medical treatment based on religious belief is also protected by Florida’s constitutional guarantee of religious freedom.
- When the state seeks to intrude on these fundamental rights, it must show a compelling interest and that the intrusion is narrowly tailored.
- The state’s interest in preserving life, while important, is not absolute against a competent adult’s informed refusal.
- The existence of minor children does not automatically supply a compelling interest to override a competent parent’s refusal; the showing must be fact-specific, including the availability of other caretakers.
Conclusion
Florida law protects a competent adult’s informed, religiously based refusal of a life-saving blood transfusion, and the state may override that decision only upon a compelling, narrowly justified showing; on these facts, concerns for life and the patient’s minor children were insufficient to compel treatment.