373 Mass. 728, 370 N.E.2d 417 (Mass. 1977)
Superintendent of Belchertown v. Saikewicz is a cornerstone case in American bioethics and health law.
Does the right to refuse life-prolonging medical treatment extend to an incompetent, terminally ill adult, and if so, by what standard and through what decision-making process should that right be exercised?
The common-law and constitutional rights of bodily integrity and privacy protect a person from unwanted medical treatment and extend to incompetent individuals. Decisions for an incompetent patient must be made under the substituted judgment standard: the decisionmaker should attempt to determine, based on the patient's values, condition, prognosis, and all relevant circumstances, what the patient would choose if competent. In extraordinary, life-and-death treatment decisions, judicial involvement is appropriate to ensure that the patient's rights are protected and that the state's interests (preserving life, preventing suicide, maintaining the integrity of the medical profession, and protecting third parties) are carefully balanced against the individual's autonomy interests.
Yes. The right to refuse medical treatment extends to incompetent individuals and should be exercised through substituted judgment. Applying that standard, the court affirmed the order authorizing the withholding of chemotherapy from Mr. Saikewicz and the provision of palliative care.
Saikewicz is a foundational case for end-of-life decision-making, establishing that incompetent adults retain the right to refuse life-sustaining treatment and that such refusals should be evaluated under the substituted judgment standard. It also marks a distinctive procedural stance: in extraordinary, life-and-death treatment choices, courts should be involved to safeguard patient rights. For law students, the case is essential for understanding the interaction of common-law consent, constitutional privacy, state interests, and guardianship principles; it also sets the stage for later decisions (state and federal) refining evidentiary standards and the role of families, physicians, ethics committees, and courts in end-of-life care.