Facts
- Washington criminalized “promoting a suicide attempt,” making it a felony to knowingly cause or aid another person to attempt suicide.
- Physicians, terminally ill patients, and a counseling nonprofit sought a declaration that the assisted-suicide ban was facially unconstitutional.
- The plaintiffs asserted that the Fourteenth Amendment’s Due Process Clause protects a liberty interest of mentally competent, terminally ill adults to choose physician-assisted death.
- The district court struck down the law, reasoning it imposed an undue burden on the asserted liberty interest.
- The Ninth Circuit (en banc) affirmed, and the Supreme Court granted review.
Issues
- Whether the Due Process Clause protects a fundamental liberty interest of competent, terminally ill adults to obtain physician assistance in committing suicide.
- If no fundamental right exists, whether Washington’s assisted-suicide prohibition is nonetheless unconstitutional under rational basis review.
Decision
- The Supreme Court reversed and upheld Washington’s assisted-suicide ban.
- The Court held that a right to assistance in committing suicide is not a fundamental liberty interest protected by the Due Process Clause.
- Because the asserted right was not fundamental, the statute was reviewed under rational basis and was sustained.
- The Court distinguished the assumed constitutional protection for refusing unwanted lifesaving treatment from a claimed right to physician-assisted suicide.
- The judgment was unanimous, with separate concurring opinions addressing doctrinal emphases and potential narrower future challenges.
Legal Principles
- Substantive due process protects only those liberties that are (1) carefully described and (2) deeply rooted in the Nation’s history and tradition.
- A claimed right to “assistance in committing suicide” is not deeply rooted in American legal tradition and therefore is not a fundamental right.
- When no fundamental right is implicated, a state law need only be rationally related to legitimate governmental interests.
- Legitimate state interests supporting assisted-suicide prohibitions include preserving human life, preventing suicide, protecting vulnerable persons from coercion or abuse, and protecting the integrity and ethics of the medical profession.
- Recognition of a right to refuse unwanted medical treatment does not entail a constitutional right to assisted suicide.
Conclusion
The Court held that the Fourteenth Amendment does not confer a fundamental right to physician-assisted suicide and upheld Washington’s prohibition because it was rationally related to legitimate state interests, leaving policy choices about assisted suicide to democratic processes.