Affirming the Legality of Assisted Suicide Prohibitions: Comprehensive Analysis of Myers et al. v. Schneiderman (2017)

Affirming the Legality of Assisted Suicide Prohibitions: Comprehensive Analysis of Myers et al. v. Schneiderman (2017)

Introduction

The case of Sara Myers et al. v. Eric Schneiderman (2017) brought forth a significant legal challenge against New York State's statutes prohibiting physician-assisted suicide, often referred to as "aid-in-dying." Filed by terminally ill patients and supported by various medical and advocacy groups, the plaintiffs sought declaratory and injunctive relief to permit mentally competent individuals with terminal illnesses to obtain lethal prescriptions from physicians. The core legal issues centered around whether such statutes violated the plaintiffs' constitutional rights under New York's Equal Protection and Due Process Clauses.

Summary of the Judgment

On September 7, 2017, the Court of Appeals of New York issued a per curiam decision affirming the lower courts' rulings that upheld the state's prohibition on assisted suicide. The court rejected the plaintiffs' arguments that aid-in-dying constitutes a fundamental constitutional right and that the statutes were not rationally related to legitimate state interests. Consequently, the court affirmed the validity of Penal Law §§ 120.30 and 125.15(3), which criminalize promoting or aiding suicide, thereby maintaining the legal barriers against physician-assisted death in New York.

Analysis

Precedents Cited

The judgment extensively referenced several key precedents that shaped its reasoning:

  • VACCO v. QUILL (1997): The U.S. Supreme Court held that New York's ban on assisted suicide does not violate the Equal Protection Clause, emphasizing that laws prohibiting assisted suicide are generally rationally related to legitimate state interests.
  • WASHINGTON v. GLUCKSBERG (1997): Another landmark Supreme Court case where the Court determined that the right to assistance in committing suicide is not a fundamental liberty interest under the Due Process Clause of the Fourteenth Amendment.
  • PEOPLE v. DUFFY (1992): Established that intent matters in distinguishing between mere refusal of treatment and active participation in suicide.
  • RIVERS v. KATZ (1986): Affirmed that the right to refuse medical treatment is a fundamental liberty interest but clarified that this does not extend to the right to assisted suicide.
  • Matter of Bezio v. Dorsey (2013): Reiterated the distinction between refusing treatment and assisted suicide, reinforcing the court's stance against statutes permitting aid-in-dying.

These precedents collectively underscored the court's commitment to differentiating between withholding or withdrawing treatment and actively assisting in death, thereby reinforcing the legality of prohibiting physician-assisted suicide.

Legal Reasoning

The court employed a rational basis review framework to evaluate the plaintiffs' claims. Under this standard, the court assesses whether the statute in question is rationally related to any legitimate governmental interest. The plaintiffs contended that aid-in-dying is a fundamental right under the Due Process Clause and that the prohibition violates equal protection.

However, the court found that:

  • The term "suicide" in Penal Law is unambiguous and encompasses aid-in-dying as defined by the plaintiffs.
  • The assisted suicide statutes are broad and universally applicable, leaving no room for exceptions based on empathetic motives.
  • The fundamental right to refuse life-saving medical treatment does not extend to the right to assisted suicide.
  • The state's interests—such as preserving life, preventing suicide, maintaining medical ethics, and safeguarding vulnerable populations—are legitimate and rationally related to the statutes.

Concluding that no fundamental right was infringed and that the statutes were rationally related to legitimate interests, the court upheld the prohibition on physician-assisted suicide.

Impact

This judgment reaffirms the legal stance against physician-assisted suicide in New York, aligning with existing federal jurisprudence. Its implications include:

  • Reinforcement of the distinction between passive refusal of treatment and active assistance in suicide.
  • Maintenance of legal barriers against aid-in-dying, preventing potential expansions of euthanasia laws in New York.
  • Upholding of medical ethics that align physicians with preserving life over facilitating death.
  • Limitation of constitutional arguments to exclude physician-assisted suicide as a fundamental right, thereby stabilizing the legal environment for end-of-life care.

Future cases challenging similar statutes may reference this decision to support the validity of assisted suicide prohibitions.

Complex Concepts Simplified

The judgment delves into intricate legal distinctions and constitutional interpretations. Here's a breakdown of key concepts:

  • Rational Basis Review: The most lenient form of judicial review where the court upholds a law if it is rationally related to a legitimate government interest.
  • Equal Protection Clause: Part of the Fourteenth Amendment ensuring no state shall deny any person within its jurisdiction "the equal protection of the laws."
  • Due Process Clause: Also part of the Fourteenth Amendment, it prohibits states from depriving any person of "life, liberty, or property, without due process of law."
  • Fundamental Right: A right deemed essential to the nation's scheme of ordered liberty, and deeply rooted in the nation's history and tradition.
  • Physician-Assisted Suicide vs. Euthanasia: Physician-assisted suicide involves the patient self-administering lethal medication prescribed by a physician, whereas euthanasia typically involves the physician actively administering the lethal dose.

Understanding these concepts is crucial to grasping the court's reasoning and the broader legal implications of the judgment.

Conclusion

The Court of Appeals of New York's decision in Myers et al. v. Schneiderman solidifies the state's prohibition on physician-assisted suicide, aligning with established federal precedents. By employing a rational basis review, the court affirmed that the assisted suicide statutes are constitutionally sound and serve legitimate state interests. This judgment not only reinforces the legal boundaries surrounding aid-in-dying but also upholds the ethical obligations of the medical profession to preserve life. The decision underscores the nuanced balance between individual autonomy in end-of-life choices and the state's role in safeguarding vulnerable populations and maintaining public morality.

As societal and medical landscapes evolve, this ruling provides a steadfast reference point for future legal challenges and legislative deliberations regarding the permissibility and regulation of physician-assisted suicide. It emphasizes the judiciary's role in interpreting constitutional protections within the context of deeply personal and ethically charged issues.

Case Details

Year: 2017
Court: Court of Appeals of New York.

Judge(s)

PER CURIAM.

Attorney(S)

Debevoise & Plimpton LLP, New York City (Edwin G. Schallert, Jared I. Kagan and Olena Ripnick–O'Farrell of counsel), and Kathryn L. Tucker, End of Life Liberty Project, of the Washington bar, admitted pro hac vice, of counsel, for appellants. Eric T. Schneiderman, Attorney General, New York City (Anisha S. Dasgupta, Barbara D. Underwood and Valerie Figueredo of counsel), for respondent. Kelley Drye & Warren LLP, New York City (Robert E. Crotty of counsel), for Michael R. Aiello, M.D. and others, amici curiae. Edward T. Mechmann, New York State Catholic Conference, New York City, amicus curiae. Adam Prizio, Albany, for Not Dead Yet and others, amici curiae. New York Civil Liberties Union Foundation, New York City (Beth Haroules and Arthur Eisenberg of counsel), for New York Civil Liberties Union, amicus curiae. Alan A. Pfeffer, Glenmont, for Alan A. Pfeffer and another, amici curiae. Mordechai Biser, Passaic, New Jersey and Avrohom Weinstock, Agudath Israel of America, New York City, for Agudath Israel of America, amicus curiae. Drinker Biddle & Reath LLP, New York City (Clay J. Pierce, Wilson M. Brown, III and Nicholas J. Stevens of counsel), for New York Chapter of the National Academy of Elder Law Attorneys, amicus curiae. Covington & Burling LLP, Washington, D.C. (Christina G. Kuhn of counsel), for American Medical Student Association and others, amici curiae. Holland & Knight LLP, New York City (Michael B. Eisenberg of counsel), for Richard N. Gottfried and others, amici curiae. Winston & Strawn LLP, New York City (Stephen L. Sheinfeld and Carla Kerr Stearns of counsel), for Betty Rollin and others, amici curiae. Chaffetz Lindsey LLP, New York City (Steven C. Schwartz and Jungmin Cho of counsel), and Law Offices of Joshua L. Dratel, P.C., New York City (Joshua L. Dratel of counsel), for National Association of Criminal Defense Lawyers, amicus curiae. Patterson Belknap Webb & Tyler LLP, New York City (Stephen P. Younger and Anthony C. DeCinque of counsel), for Vincent Bonventre and others, amici curiae. Hennessey & Bienstock LLP, New York City (Patricia Hennessey of counsel), and Verrill Dana LLP, Boston, Massachusetts (Thomas O. Bean of counsel), for Unitarian Universalist Association and others, amici curiae. Wilmer Cutler Pickering Hale and Dorr, New York City (David B. Bassett of counsel), and Kevin Díaz, Compassion & Choices, Portland, Oregon, for Compassion & Choices, amicus curiae.

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