Bouvia v. Superior Court, 179 Cal. App. 3d 1127, 225 Cal. Rptr. 297 (Cal. Ct. App. 1986)
Bouvia v. Superior Court is a landmark California decision at the intersection of constitutional privacy, common-law bodily autonomy, and medical ethics.
Does a competent adult patient have the right to refuse artificial nutrition and hydration and to prevent a hospital from forcibly administering such treatment, even when the refusal will foreseeably result in the patient's death and regardless of the patient's motives?
Under California law, a competent adult has both a constitutional right of privacy (Cal. Const., art. I, § 1) and a common-law right to bodily integrity and self-determination that encompass the right to refuse any medical treatment, including life-sustaining measures such as artificial nutrition and hydration, regardless of motive or prognosis. Forced medical treatment constitutes a battery in the absence of informed consent. The state's interests in preserving life, preventing suicide, protecting third parties, and maintaining the ethical integrity of the medical profession do not outweigh a competent patient's right to refuse treatment unless extraordinary circumstances are shown; a patient need not be terminally ill or imminently dying to exercise this right.
Yes. The Court of Appeal held that a competent adult has the right to refuse artificial nutrition and hydration and ordered relief to prevent the hospital from forcibly feeding Bouvia. The court directed that the nasogastric feeding tube be removed and that the hospital respect Bouvia's decision while providing appropriate palliative care.
Bouvia is a foundational case in patient autonomy and end-of-life law. It firmly establishes that competent adults may refuse artificial nutrition and hydration and that such refusal is not legally equated with suicide. The decision clarifies that terminal illness is not a prerequisite to exercise the right to refuse treatment and that hospitals must honor a competent patient's informed refusal while still providing palliative care. For students, it illustrates how courts balance individual rights against state interests and how informed consent principles extend to informed refusal. The case influenced later statutory and case developments in California and nationally, shaping clinical policies on advance directives and withdrawal or withholding of life-sustaining interventions.