Home > Case Studies, History of PSDA > What happened BEFORE the PSDA? Karen Quinlan Case

What happened BEFORE the PSDA? Karen Quinlan Case

The landmark case of Karen Ann Quinlan was the firstthe first to deal with the dilemma of withdrawing life-sustaining treatment from a patient who was not terminally ill but who was not really “alive.” The decision to terminate life support, which was once a private matter between the patient’s family and doctor, became an issue to be decided by the courts. The New Jersey Supreme Court ruling on this case became the precedent for nearly all right-to-die cases nationwide.

What happened?

In 1975, 21-year-old Karen Ann Quinlan suffered cardiopulmonary arrest after ingesting a combination of alcohol and drugs. She subsequently went into a persistent vegetative state (PVS). Dr. Fred Plum, a neurologist, described her as no longer having any cognitive function but retaining the capacity to maintain the vegetative parts of neurological function. She grimaced, made chewing movements, uttered sounds, and maintained a normal blood pressure, but was entirely unaware of anyone or anything. The medical opinion was that Quinlan had some brain-stem function, but that in her case it could not support breathing. She had been on a respirator since her admission to the hospital.

What rights did Karen’s family have in the situation?

Quinlan’s parents asked that her respirator be removed and that she be allowed to die. Quinlan’s doctor refused, claiming that his patient did not meet the Harvard Criteria for brain death. Based on the existing medical standards and practices, a doctor could not terminate a patient’s life support if that patient did not meet the legal definitions for brain death. According to the Harvard Criteria, Quinlan could not be declared legally dead, and medical experts believed she would die if the respirator were removed.

Julia and Joe Quinlan lost their initial court petition in Superior Court, but they persisted, and brought their case before the New Jersey Supreme Court. On March 31, 1976, the New Jersey Supreme Court rendered a unanimous decision appointing Joe Quinlan as the personal guardian of their daughter Karen with the right to determine her medical treatment, including the right to discontinue all extraordinary means of life support.

The Health Care Providers side.

Quinlan’s physicians had refused to remove the respirator because they did not want to violate the prevailing medical standards and practices. Even though Quinlan’s physicians assured the court that the possibility of lawsuits and criminal sanctions did not influence their decision in this specific case, the court believed that the threat of legal ramifications strongly influenced the existing medical standards and practices of health care providers.

The court also observed that life-prolongation advances had rendered the existing medical standards ambiguous (unclear), leaving doctors in a quandary. Moreover, modern devices used for prolonging life, such as respirators, had confused the issue of “ordinary” and “extraordinary” measures. Therefore, the court suggested that respirators could be considered “ordinary” care for a curable patient, but “extraordinary” care for irreversibly unconscious patients.

The court suggested that hospitals form ethics committees to assist physicians with difficult cases like Quinlan’s. These committees would be similar to a multi-judge panel exploring different solutions to an appeal. The committees would not only diffuse professional responsibility, but also eliminate any possibly unscrupulous motives of physicians or families. The justices considered the court’s intervention on medical decisions an infringement on the physicians’ field of competence.

Is It Homicide?
The state had promised to prosecute anyone who terminated Quinlan’s life support because such an act would constitute homicide. The New Jersey Supreme Court, however, rejected this consequence because the resulting death would be from natural causes. The court stated:

The exercise of a constitutional right, such as we have here found, is protected from criminal prosecution.… The constitutional protection extends to third parties whose action is necessary to effectuate the exercise of that right.…

After the Respirator Was Removed

In March 1976 the New Jersey Supreme Court ruled that, if the hospital ethics committee agreed that Quinlan would not recover from irreversible coma, her respirator could be removed. Furthermore, all parties involved would be legally immune from criminal and civil prosecution. However, after Quinlan’s respirator was removed, she continued to breathe on her own and remained in a PVS until she died of multiple infections in 1985.

The ruling gave patients and families the right to live each stage of life, including the last stage, with dignity and respect, and for medical institutions such as hospitals, hospices and nursing homes that would now be required to establish and maintain ethics committees. In addition, the Quinlan case led to the creation of the “living will,” sometimes called an “advanced directive,” which outlines the personal wishes of the individual in regard to “extraordinary means” to maintain life.

Information retrieved from:

Karen Quinlan Memorial Foundation

Court and the End of Life – The Right To Privacy: Karen Ann Quinlan


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