## Facts

- New York criminal law made it a felony to intentionally cause or aid another person to commit suicide and separately prohibited intentionally aiding an attempted suicide.
- New York law and medical practice permitted competent patients to refuse even life-saving medical treatment, including withdrawal of life support.
- Physicians and terminally ill patients challenged the assisted-suicide ban, asserting that prescribing lethal medication to mentally competent, terminally ill patients in severe pain could be consistent with sound medical practice.
- The challengers alleged they were deterred from providing or obtaining such assistance by the threat of criminal prosecution.
- A federal district court upheld the ban, finding rational state interests in preserving life and protecting vulnerable persons.
- The court of appeals reversed, reasoning that the State irrationally treated similarly situated terminally ill patients differently by allowing withdrawal of life support but forbidding physician-assisted suicide.
- The Supreme Court granted review to decide whether the challenged distinction violated the Equal Protection Clause.

## Issues

1. Whether a state violates the Equal Protection Clause by permitting competent patients to refuse life-sustaining treatment while criminalizing physician-assisted suicide.
2. Whether the asserted differential treatment between withdrawing treatment and prescribing lethal medication is irrational under the Fourteenth Amendment.
3. What level of scrutiny applies to an equal protection challenge to a state assisted-suicide prohibition.

## Decision

- The Supreme Court unanimously reversed the court of appeals and upheld New York’s prohibition on assisting suicide.
- The Court applied rational basis review because the statutes neither burdened a fundamental right nor drew a suspect classification.
- The Court held that New York could distinguish between refusing life-saving treatment and physician-assisted suicide because the acts differ in causation and intent.
- The Court concluded that the assisted-suicide ban was rationally related to legitimate state interests, including preserving life, protecting vulnerable persons, maintaining medical ethics, and preventing euthanasia and abuse.
- Concurring Justices emphasized that aggressive palliative care, including pain medication that may foreseeably hasten death, remains lawful when intended to relieve suffering rather than cause death.

## Legal Principles

- Equal protection generally requires like cases to be treated alike, but permits different treatment of materially different conduct.
- A facially evenhanded rule that allows competent patients to refuse unwanted treatment while forbidding anyone from assisting suicide does not, by itself, create an equal protection violation.
- Withdrawing or withholding life-sustaining treatment may be treated differently from assisted suicide because death is attributed to the underlying disease and the actor’s intent may be to respect refusal of treatment or relieve pain, not to cause death.
- Assisting suicide may be prohibited based on the actor’s intentional participation in causing death.
- When no fundamental right or suspect class is implicated, an assisted-suicide prohibition is upheld if rationally related to legitimate state interests.

## Conclusion

The Court held that New York’s assisted-suicide ban does not violate equal protection because the State may rationally treat refusal of medical treatment and assisted suicide as different acts and may criminalize assisted suicide to further legitimate interests in preserving life, protecting vulnerable persons, and regulating medical ethics.


Vacco v. Quill, 521 U.S. 793 (1997)