## Facts

- Theresa Marie Schiavo suffered cardiac arrest in 1990 and remained in a persistent vegetative state, receiving nutrition and hydration through a feeding tube.
- Michael Schiavo, as her legal guardian, sought and obtained Florida state-court authorization to withdraw artificial nutrition and hydration under substituted-judgment principles.
- After extensive evidentiary proceedings, the state trial court found by clear and convincing evidence that Theresa would have declined continued artificial nutrition and hydration.
- The Schindlers (Theresa’s parents), acting as next friends, opposed withdrawal and pursued repeated state-court challenges and appeals; the state-court authorization remained in effect.
- In March 2005, after Congress enacted a statute granting federal jurisdiction for review of alleged federal-rights violations relating to Theresa’s case, the Schindlers filed suit in federal district court.
- The complaint alleged violations of procedural and substantive due process, equal protection, free exercise of religion, and RLUIPA.
- The Schindlers moved for a temporary restraining order requiring transport for medical treatment and restoration of nutrition and hydration.

## Issues

1. Whether plaintiffs showed a substantial likelihood of success on the merits of federal claims alleging constitutional and RLUIPA violations arising from the state-court process authorizing withdrawal of artificial nutrition and hydration.
2. Whether plaintiffs established irreparable harm absent a temporary restraining order.
3. Whether the balance of harms favored compelling restoration of nutrition and hydration notwithstanding final state-court rulings.
4. Whether the public interest supported federal injunctive relief that would effectively displace long-running state adjudications.

## Decision

- The district court denied the motion for a temporary restraining order.
- Plaintiffs failed to show a substantial likelihood of success on the merits, which was dispositive under the four-factor injunctive-relief test.
- The court determined the state-court proceedings provided adequate procedural protections and did not likely violate due process.
- The court concluded plaintiffs were unlikely to succeed on equal protection because Florida’s end-of-life decision framework was rationally related to legitimate state interests.
- The court found plaintiffs were unlikely to succeed on free exercise and RLUIPA claims because the challenged actions applied neutral, generally applicable law and did not show a substantial burden on Theresa’s religious exercise attributable to government action.
- Although death constituted irreparable harm, irreparable harm could not justify relief without a sufficient showing of likely success.
- Comity and federalism concerns weighed against federal intervention that would effectively nullify final state-court judgments.

## Legal Principles

- Temporary restraining orders are extraordinary relief; the movant must establish: (1) substantial likelihood of success on the merits, (2) irreparable injury, (3) balance of harms favoring relief, and (4) consistency with the public interest.
- A jurisdiction-conferring federal statute permitting federal review does not eliminate traditional equitable requirements for injunctive relief.
- Extensive, adversarial state-court litigation can satisfy procedural due process where the party had meaningful opportunities to be heard and appellate review.
- Equal protection challenges to end-of-life decision statutes generally receive rational-basis review absent a suspect classification or separate showing of a burden on a fundamental right.
- Free exercise and RLUIPA claims require more than disagreement with outcomes reached under neutral, generally applicable laws; RLUIPA requires a government-imposed substantial burden on the individual’s religious exercise.

## Conclusion

The federal district court refused to order restoration of nutrition and hydration because plaintiffs did not meet the required showing for emergency injunctive relief, particularly a substantial likelihood of proving federal constitutional or RLUIPA violations in light of the extensive state-court proceedings and the public interest in respecting final state judgments.


Schiavo ex rel. Schindler v. Schiavo, 357 F. Supp. 2d 1378 (M.D. Fla. 2005)