Constitutional Law (Substantive Due Process; Right to Die)
79 F.3d 790 (9th Cir. 1996) (en banc)
Study notes for Compassion in Dying v. Washington: professor notes, cold call prep, exam angles, and memory aids.
Competent, terminally ill adults have a constitutional right to seek physician-assisted suicide under the Due Process Clause.
In Compassion in Dying v. Washington, the Ninth Circuit addressed the pivotal issue of whether a competent, terminally ill adult has the constitutional right to choose physician-assisted suicide under the Fourteenth Amendment's Due Process Clause. The court emphasized the importance of personal autonomy and the deeply rooted notions of liberty that include the right to make decisions concerning one's own body and life, especially when faced with terminal illness. The court concluded that Washington's blanket ban on physician-assisted suicide unjustly infringed upon this right, failing to provide a narrowly tailored approach to the state's interests in preserving life and preventing coercion.
The opinion also highlighted the contrasting moral and ethical views surrounding end-of-life decisions, noting that while the state has a legitimate interest in regulating medical practices, it must balance that interest against fundamental individual liberties. Students should note how the court’s interpretation of substantive due process in this case highlights the evolving nature of constitutional rights, especially in light of changing societal views on issues such as assisted dying.
DIE: Due Process Includes End-of-life choices.
| Case | Distinction |
|---|---|
| Washington v. Glucksberg | In Glucksberg, the Supreme Court upheld a similar ban, framing the liberty interest differently and emphasizing traditional state interests in life preservation. |
| Cruzan v. Director, Missouri Department of Health | Cruzan involved the right to refuse treatment rather than the right to assist in dying, focusing more on the patient's autonomy and decision-making capacity. |
| Rennie v. Klein | Rennie addressed the rights of patients with mental illness rather than terminally ill patients, exploring statutory interpretations of autonomy in healthcare. |
Allowing physician-assisted suicide respects individual autonomy and provides dignity in death for terminally ill patients.
There are concerns about the potential for coercion and the sanctity of life that may undermine vulnerable populations.
This case is often examined in the context of substantive due process and individual rights, making it a crucial reference point for questions about the limits of state regulation on personal autonomy and end-of-life decisions.