Introduction
Karen Ann Quinlan is a prominent figure in the “right to die” controversy under United States jurisprudence. The main issue in her case arose when her family sought the court’s order that she be allowed to die by removing any life support connected to her. This request received opposition from the hospital who took care of Ms. Quinlan.
Ms. Quinlan was diagnosed as being in a permanent coma after she collapsed at a party where she consumed alcohol and drugs. She was kept alive on a ventilator. Her feeding also required a nasogastric tube. On account of her persistent vegetative state, Ms. Quinlan’s father went to court seeking authority to remove her respirator. The hospital heavily opposed this move.
Her case is a very highly publicized controversy. It continues to uproot the moral question relating to the preservation of life and euthanasia. Her case also brought about the formation of formal ethics committees in hospitals and the development of advance health directives.
Karen Ann Quinlan
Right after she just turned 21 in April 1975, Ms. Quinlan moved out of her parents’ home and into a new house a few miles away. She lived there with two roommates. According to Spiritus-Temporis.Com, she was obsessed about her weight that she went on a radical diet. Her idea was to starve herself so that she would fit into her newly-bought dress. (http://www.spiritus-temporis.com/karen-ann-quinlan/)
On April 15, 1975, Ms. Quinlan went to a friend’s party at a local bar. It was reported that she did not eat for two days already pursuant to her radical diet. At the party, she had consumed large quantities of drugs and alcohol. She was seen consuming gin and tonics. It was also reported that she took a tranquilizer, which she thereafter suddenly felt faint. Then she passed out.
Her friends took her home and placed her in bed. When they checked back on her, they found her looking pale and no longer breathing. Her friends called the police of Sussex County, New Jersey. (http://www.ou.edu/englhale/quinlan.html)
According to reports, she had ceased breathing for at least two instances at 15-minute periods. Her friends attempted to resuscitate her. When the police arrived, they applied a respirator on her. They loaded her on an ambulance and then took her to the hospital.
Ms. Quinlan was diagnosed as being in a coma when she was admitted to Newton Memorial Hospital in New Jersey. She stayed there for nine days in an unresponsive state until she was transferred to St. Clare’s Hospital. The doctors described her condition as decorticate; a condition in which the brain cortex does not share in the bodily functions.
According to the University of Maryland Medical Center, a decorticate posture denotes a damage to the corticospinal tract, thus signifying a severe damage to the brain. In such a condition, “the upper arms are drawn into the side of the body. The forearms are drawn in against the chest with the hands generally at right angles to the forearms, pointing towards the waist. The legs are drawn up against the body, knees are up, and feet are in near the buttocks and extended in a ballet-type pose.” (http://www.umm.edu/ency/article/003300.htm)
Persistent Vegetative State
When Ms. Quinlan was admitted in the hospital, her doctors found out that she had suffered irreversible brain damage after she experienced an extended period of respiratory failure of at least 15 minutes. The doctors could not pinpoint the precise cause of her respiratory failure. They could only speculate that it was caused when she passed out and aspirated on her own vomit.
After a careful study of her brain, the doctors found scarring in her cerebral cortex. Her thalamus, however, was severely damaged, which explains why she was in a coma. Her brain stem, on the other hand, was undamaged.
Medical reports also stated that her eyes were no longer moving in the same direction together. It also disclosed that although Ms. Quinlan did not have a flat electroencephalograph, it showed abnormal slow-wave activity. Nonetheless, this is proof that she was “not brain dead.”
Due to the constant threat of infection, Ms. Quinlan was regularly given antibiotics. She was sweating almost every time. In addition, she had lost her ability to maintain necessary bodily functions like breathing or urinating, unless assisted by medical instruments.
Medical attention was always on the clock. Nurses were constantly moving here in order to avoid edema. Despite the number of tests carried out, the doctors could not discover the cause of the coma. However, they believed her previous respiratory failures for about 15 minutes in each instance contributed to the damage to her brain.
Over seven months have passed since her confinement yet there were no signs of improvement. According to Ascencion Health, the doctors have surmised that she is under the condition commonly known in current terminology as “persistent vegetative state.” (http://www.ascensionhealth.org/ethics/public/cases/case21.asp)
During her years of vegetative state, she was fed through a nasogastric tube in which her nutrition and hydration passes. She was also assisted by a respirator since she had difficulty breathing on her own.
The doctors, however, observed that Ms. Quinlan was capable of breathing on her own but only for short periods. Muscle activity was also shown, which some doctors opined that it was voluntary.
During the next few months, Ms. Quinlan’s lost weight that she even reached her lightest at 36 kilograms. Basically, her condition gradually worsened. It was told that only her nasogastric feeding tube and her ventilator had kept her alive for the most part of her life in the hospital.
After a tedious legal battle whether to keep her life support system continued, her respirator was ordered by the New Jersey Supreme Court to be disconnected. Despite the disconnection, she was able to breathe on her own. When asked if the nasogastric tube would also be removed, his father opted that it stays there saying God would determine when her daughter would die.
Ms. Quinlan lived for the next nine years. She died on June 11, 1985 in a New Jersey nursing home. Her death was due to complications from her pneumonia.
Legal Battle
Ms. Quinlan’s family had lost all hope for her. They can no longer bear to see her like this. In view of her deteriorating condition, her father, Joseph T. Quinlan, decided that it was time for the doctors to remove the ventilator. Accordingly, Joseph instructed the doctors at St. Clare’s Hospital to disconnect her life support, thus allowing her to die.
Hospital officials opposed. They said that removing the system was tantamount to killing Ms. Quinlan. This opposition was supported by the local prosecutor and the state attorney general.
According to the website Judgegeorgegreer.com, the doctors asserted that Ms. Quinlan is very much alive, both legally and medically. They added that the act of disconnecting the life support is an act of mercy killing and homicide. The doctors’ stance was that the matter involved a medical decision; hence, they should be the one to decide whether or not to pull the plug on Ms. Quinlan. (http://judgegeorgegreer.com/images/quinlan.htm)
As the attending physicians, they averred that they must do everything in their ability to sustain Ms. Quinlan’s as it is their moral duty and professional obligation to do so. They added that they never said that there was no hope for recovery. What they said was that the chances were slim.
Her father sought the lower court’s order appointing him to be the guardian of his 21 year-old daughter. He also asked for the court’s order authorizing the discontinuance of all extraordinary medical procedures as well as life support systems attached to Ms. Quinlan.
The lower court denied her father’s requests. The judge decided that the authorization sought by her Ms. Quinlan’s father was to permit her to die, which is something adverse to her best interests. The court also added that the matter would be best left for the doctors to decide since it involved a medical decision, thus, Ms. Quinlan’s life support stayed.
Accordingly, the Quinlan family brought the case up to the New Jersey Supreme Court. They argued that under legal and medical definitions recognized under New Jersey laws, Ms. Quinlan is dead on account of her condition. They asserted that there was no hope of her “eventual recovery” in relation to her “alleged irreversible coma and physical debility.”
The High Court reversed the lower court’s order. Ms. Quinlan’s father was appointed as the guardian of her daughter.
The Supreme Court also redefined the concept of the right to privacy in this case. In the lower court, the judge rationalized that the preservation of life necessarily prevails over the parents’ assertions of Ms. Quinlan’s right to privacy. The concept of right of privacy, as used in this case, meant that the doctors could administer various medical treatments as may be necessary for the patient’s recovery despite the latter’s objections grounded on the latter’s right to privacy.
With regards to the question on right to privacy, the High Court overturned the decision of the lower court, thus permitting Ms. Quinlan’s father to disconnect the life support from her daughter.
The respirator was disconnected yet Ms. Quinlan still kept on breathing. When asked if the nasogastric tube would also be removed, his father opted that it stay there saying God would determine when her daughter would die.
The High Court enunciated that the State cannot compel Ms. Quinlan to suffer the agonizing invasion of her body with various medical devices and contraptions with no realistic chance of her recovery. In this case, Ms. Quinlan’s right to privacy prevailed over the doctors’ rights to administer medical treatment according to their best judgment and discretion.
Moreover, the decision even raises the Ms. Quinlan’s right to privacy as superior to the State’s compelling interest in preserving life. As held in this case, “the individual’s right to privacy grows as the degree of bodily invasion increases and the prognosis dims.”
Thus, the lesser chance a patient has in his recovery to conscious life, the less right the state has to compel medical treatment upon him.
Impact of the Quinlan Case on the Medical Community
The Quinlan case has left a profound influence in the medical, as well as legal community. One of these impacts includes the development of formal ethics committees in hospitals, nursing homes and in other similar institutions.
During the time of the Quinlan case, ethics committees were unheard of. Doctors were confronted with the predicament concerning the use of their independent medical judgment relating to the disposition of their dying patients. Some doctors admitted that they are ill-equipped to make a sound judgment.
Ms. Quinlan’s case opened up doors for the establishment of these ethics committees in hospitals. These committees are composed of physicians, social workers, lawyers and theologians. Their tasks tackle the ethical aspect in the hospital setting. They review individual circumstances affecting moral questions relating to the preservation of life. In addition, they also provide advice and assistance for patients and their medical caretakers.
Moreover, the Karen Ann Quinlan Memorial Foundation adds the High Court’s ruling paved the way for patients and their families the “right to live each stage of life with dignity and respect.” (http://www.karenannquinlanhospice.org/History.htm)
Judgegeorgegreer.com adds that the case also conceptualized a new definition of death in some states, and even prompted the adoption of laws recognizing the right to die. Accordingly, a patient may outline his preference over the use of extraordinary means to maintain life. In addition, a guardian may, on the patient’s behalf, make health care decisions. Thus, artificial feeding could be withheld from terminally ill patients if it can be shown that it is in accord with the latter’s wishes. (http://judgegeorgegreer.com/images/quinlan.htm)
The Quinlan case also gave birth to the right to die movement. Prior to this case, the State may compel a patient to undergo medical treatment despite the latter’s objection on account of his right to privacy. This would mean that the doctors have the right to administer medical treatment to a patient notwithstanding his protest. With the Quinlan case, this was reversed.
This case has been very significant. It marked a new era as the Supreme Court ordered that an individual’s right to privacy prevails over the State’s interest regarding the preservation of life.
Another important milestone set by the Quinlan case was that it influenced the medical community as it redefined the meaning of death. In the past, death was limited to the cessation of heart and blood circulation. However, in view of modern medical instruments and measures, an individual could still have a heart beat and be kept alive through respiratory ventilators, and yet lack any brain activity.
With the advent of the Quinlan case, the concept of death was expanded to include “brain death,” wherein there is an absence of response to pain or other stimuli, papillary reflexes, blood pressure, flat respiration and flat electroencephalograms.
The brain has basically two categories: (i) vegetative, and (ii) cognitive. The vegetative aspect controls our basic bodily functions like breathing, sleeping, blood pressure, heart rate, etc. On the other hand, the cognitive functions relate to our interactions with the outside world by talking, smelling, hearing, seeing, and thinking, among others. The presence of any of these functions would mean that the brain is not biologically dead.
Conclusion
The Quinlan case is a matter of transcendental significance. This landmark case was the first to tackle the question of withdrawing the life support system from a person under a permanent vegetative state.
As held in the case, the patient has the right to refuse medical treatment as his right to privacy from the agonizing intrusion of medical instruments prevail over the State’s interest over the preservation of life. Accordingly, the doctors cannot assert their right to administer medical treatment on a patient over the latter’s objection.
The case acknowledged the patient’s right to die. This moral and ethical question has long been evaded due to the conflict resulting from the professional obligation of the doctors, on one hand, and, on the other, the emotional distress suffered by the patient’s loved ones seeing him there suffering. Naturally, the issue would boiled down to the issue of euthanasia.
The case also redefined the concept of death. It appropriately conceptualized the new meaning of death in view of the rapid advancement of medical technology since one can prolong its life through artificial means.
The long-standing definition of death as the cessation of vital bodily functions have become obsolete since a person may still be able to breathe through ventilators or respiraors yet lacking any brain activity. Accordingly, the scope of death was rightfully expanded to include “brain death.”
Sources
Biography of Karen Ann Quinlan
http://www.spiritus-temporis.com/karen-ann-quinlan/
THE MATTER OF KAREN QUINLAN
http://www.ou.edu/englhale/quinlan.html
Overview on Decorticate posture — University of Maryland Medical Centre
http://www.umm.edu/ency/article/003300.htm
Quinlan, Karen Ann
http://www.ascensionhealth.org/ethics/public/cases/case21.asp
Karen Ann Quinlan Memorial Foundation
http://www.karenannquinlanhospice.org/History.htm
In The Matter Of Karen Quinlan An Alleged Incompetent
Supreme Court of New Jersey — 70 N.J. 10; 355 A.2d 647; 1976
http://judgegeorgegreer.com/images/quinlan.htm
