Facts and Court Holding
Karen Ann Quinlan attracted national attention following her slipping into a comma in 1975. In essence, the Quinlan case remains a key reference point in discussions revolving around the right to die. According to Drane (1994) Ms. Quinlan fell into a comma on the night of April 15, 1975 following her an evening birthday party of one of her friends. It was reported that during the party, Quinlan took a cocktail of alcoholic beverages. In additional to alcohol, it was also reported that she took a tranquilizer (Valium to be specific) (Drane, 1994). She promptly slid into a comma. Soon, her friends realized she was not breathing and called an ambulance which rushed her to Newton Memorial Hospital. Efforts to resuscitate Quinlan were unsuccessful and after it became apparent that her comma was irreversible, she was transferred to another medical facility, i.e. St. Clare’s in Danville.
After a while, Quinlan was declared to be in a persistent vegetative state. The condition she was in could not be reversed. It was after she was to be declared to be in a persistent vegetative state that her parents sought to intervene and end what they saw as her unnecessary suffering. According to Quinlan’s patients, chances of their daughter returning from the state she was in were slim at best. Thus, to end her suffering, the said parents made a private request to doctors at St. Claire’s in Danville that the machines being used to sustain Quinlan be switched off (Rosenthal, 2018). Quinlan’s parents proceeded to seek the intervention of the court following the refusal by doctors at the healthcare facility to heed to their request. It is this move that set the stage for what came to be an intense national debate on the question of life and death, and the right to die.
On September 1985, Quinlan parents filed a suit seeking termination of further attempts to prolong the life of their daughter using extraordinary means. However, a month since the suit’s filing, this particular request was denied by a Superior Court judge in Morristown, New Jersey (Rosenthal, 2018). According to Rosenthal (2018), the judge in this case argued that the decision to remove Quinlan from the ventilator was not supported by her doctors. Here, the judge made a finding that the decision at hand was more medical than judicial. As Rosenthal (2018) further points out, it was also found that any move to disconnect the respirator would in this particular case be in contravention of the homicide statuses of New Jersey State.
The loss of the petition did not deter Quinlan’s parents from their resolve to end what in their opinion was the unnecessary suffering of their daughter. They, thus, moved to the New Jersey Supreme Court. In what came to be seen as a landmark ruling, the Supreme Court granted the wish of Quinlan’s parents – arguing, in part, that Quinlan ought not to endure that which appeared unendurable. The court, to be more specific, “held a new interpretation of the right of privacy, and that Miss Quinlan’s interest in having her life-support systems disconnected exceeded the state’s interest in preserving life, so long as medical authorities saw ”no reasonable possibility” that she would recover” (Karen Ann Quinlan Hospice, 2019). Further, according to Karen Ann Quinlan Hospice (2019), the court also made a finding that if Quinlan’s death did result from the disconnection of the respirator, then her death would be as a consequence of existing natural consequences. This is to say that under such circumstances, the course of action adopted by the doctors would not be homicide and, thus, the said doctors would not be held criminally liable. It was also determined that Quinlan’s condition at the time meant that her father was the one having the authority to make decisions on her behalf. The implication of this finding was that the court and doctors had no say on this front.
In the end, Quinlan was weaned from the respirator. She ended up surviving for close to a decade. Her condition and wellbeing, however, deteriorated over time. She died in on June 11th, 1985. It is important to note that at the time Quinlan was admitted to hospital, she weighed 115 pounds. However, at the time of her death, she weighed only 65 pounds (Drane, 1994). Quinlan’s death was attributed to pneumonia which ended up triggering respiratory failure. Drane (1994) points out that her family had already requested that the hospital makes no attempt to revive her. In their opinion, any attempt to revive Quinlan would be unnatural, unnecessary, and inappropriate.
Hospital and Parent Beliefs
According to Quinlan’s parents, failure to disconnect Quinlan from the ventilator was, as Rosenthal (2018) points out, tantamount or equivalent to the extension of her life extraordinarily. In their opinion, this was a move that not only caused her suffering and discomfort, but also a lot of unnecessary pain. On the other hand, doctors pointed out that Quinlan did not adequately satisfy the brain death criteria. What this argument meant, in basic terms, is that as per the medical standards at the time, Quinlan was not yet legally dead. It is important to note that the hospital’s refusal to grant the private request of Quinlan’s parents was also based on the fear of homicide charges. The state of New Jersey, as Drane (1994) observes, had waded in into the debate warning that any person found to have played a role in ending the life of Quinlan would be promptly prosecuted. For this reason, the hospital sought the protection of the law by joining the parents of Quinlan in court. It would also be prudent to assess the opinion of Ms. Quinlan’s court appointed guardian. According to Rosenthal (2018), the said court appointed guardian was of the opinion that switching off the machines being used to sustain Quinlan would amount to homicide. It, therefore, follows that as per this perspective, the court was being asked to rubber-stamp an illegality. With the court pronouncing itself on the matter, the medical profession was invited to make use of the ruling as a guideline for future decisions. This meant that doctors now had the necessary legal protections to withhold measures deemed extraordinary (upon the private request of the family members) to keep patients with terminal or debilitating illnesses alive. Years later, the entire debate was turned into what ought to (or ought not to) be considered ‘life’. In this case, a clear distinction has been sought between ‘life’ and ‘death’. Thus, in the words of Holland, Kitzinger, and Kitzinger (2014), from a legal perspective, there have been attempts by courts of law “to honor the wish to preserve human dignity while still fulfilling their mandate to prevent murder” (415).
End of Life Issues
There are several issues brought up in the Quinlan case that relate to end of life. The most prominent ones, in my opinion, relate to the diagnosis of permanent vegetative state and the right to die with dignity. From a general perspective, my preferences are in line with those of Quinlan’s parents. This is to say that when a patient slides into an irreversible coma and is declared to be in a permanent/persistent vegetative state, any attempt to prolong life that causes the said patient discomfort or suffering is not only inappropriate, but also unnecessary. It is important to note that when in a persistent vegetative state, the patient does not possess the ability to make decisions. This is to say that the autonomy of the patient is largely compromised. On this front, autonomy could be defined as respect for the wished of the patient (Mizzoni, 2011).
As human beings, we expect to be allowed or permitted to make decisions without undue influence from outsiders. This is as long as those decisions do not have a negative effect on the wellbeing of other people. It, therefore, follows that patients possess the right to make key decisions relating to their care in medical settings. This is, however, only possible in those instances whereby the patient is conscious and capable of comprehending the consequences of the choices that they make. In a persistent vegetative state, the patient happens to be permanently unaware of the happenings around them. In such a case, someone ought to step in to make decisions that are in the best interests of the patient. Such a person is referred to as an alternate decision maker.
In some instances, patients could have made an advance directive with regard to their preferred alternate decision maker. This could be done via “a legal document that records treatment preferences or designates a durable power of attorney for health care, or both” (Singer, 2013). However, in instances whereby there is no advance directive or when patients do not have surrogates, there are several approaches that could be embraced. In a case involving an unrepresented patient who happens to be in a permanent vegetative state, a physician or an ethical committee could be the designated decision maker. This could be the case pending the appointment of a guardian. As a matter of fact, the AMA Code of Medical Ethics points out that in situations that involve patients with no surrogate and are incapable of making decisions, the ethics committee ought to be consulted by physicians on key decisions (Singer, 2013). In the case of Quinlan, it was possible for the court to identify a guardian, i.e. her dad. In such a case, the guardian is granted legal authority in as far as all decisions appertaining to the incapacitated person are concerned. In those instances whereby the patient is in permanent vegetative state, it is the responsibility of the guardian to make decisions that are in the best interests of the patient.
This brings us to the question on what the best interests of a patient are in a situation such as that of Quinlan. People ought to be granted the benefit of dying with dignity. When a patient sinks to a state of irreversible suffering, and there are no medical interventions likely to improve their wellbeing, I am of the opinion that the best course of action would be to end the suffering of such a patient. This would be in line with advancing the right of a patient to die with dignity. Further, it advances the assertion that as human beings, we have an inalienable right to live with dignity. Allowing the prolonged suffering of an individual goes against this standard. In the final analysis, it should be noted that from the perspective of justice, “US case law has shown that successful petitions for termination have been made after a diagnosis of a persistent vegetative state” (Singer, 2013, p. 113). This was clearly what happened in the case of Karen Ann Quinlan.
References
Drane, J.F. (1994). Clinical Bioethics: Theory and Practice in Medical Ethical Decision-making. New York, NY: Rowman & Littlefield.
Holland, S., Kitzinger, C. & Kitzinger, J. (2014). Death, treatment decisions and the permanent vegetative state: evidence from families and experts. Med Health Care Philos., 17(3), 413-423.
Karen Ann Quinlan Hospice (2019). The Story of Karen Ann Quinlan Made Headlines! Retrieved from https://www.karenannquinlanhospice.org/about/history/
Mizzoni, J. (2011). Ethics: The Basics. Hoboken, NJ: John Wiley & Sons.
Rosenthal, M.S. (2018). Clinical Ethics on Film: A Guide for Medical Educators. New York, NY: Springer.
Singer, P. (2013). A Companion to Ethics. Hoboken, NJ: John Wiley & Sons.
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