State Residency Limits on Medical Aid in Dying and the Privileges and Immunities Clause: Commentary on Dr. Paul Bryman v. Phil Murphy

1. Introduction

The Third Circuit’s precedential decision in Dr. Paul Bryman v. Phil Murphy addresses a novel and sensitive question at the intersection of constitutional law, medical ethics, and federalism: whether a state that legalizes physician-assisted suicide (or “medical aid in dying”) may confine that option to its own residents without violating the U.S. Constitution.

New Jersey’s 2019 Medical Aid in Dying for the Terminally Ill Act authorizes physicians to prescribe lethal medication to terminally ill patients who satisfy stringent procedural safeguards. Critically, however, the Act restricts eligibility to New Jersey residents. The plaintiffs—a New Jersey physician, Dr. Paul Bryman, and (originally) out-of-state terminally ill patients—argued that this residency requirement violates:

Article IV’s Privileges and Immunities Clause,
the Equal Protection Clause of the Fourteenth Amendment, and
the so‑called dormant Commerce Clause.

Judge Bibas, writing for a unanimous panel (Judges Bibas, Montgomery-Reeves, and Ambro), rejects all three theories and affirms the District Court’s dismissal. The opinion is doctrinally significant in at least three ways:

It sharply limits the lingering force of Doe v. Bolton (the companion case to Roe v. Wade) as a Privileges and Immunities precedent after Dobbs.
It confirms that medical aid in dying is not a “fundamental privilege” protected for out-of-state visitors under Article IV, and that even if access to medical care were such a privilege, a state may impose residency limits where it has substantial, well-tailored reasons.
It clarifies that challenges to residency-based access to morally charged medical services belong primarily under Privileges and Immunities, not under the dormant Commerce Clause.

In practical terms, the case provides a robust constitutional defense of residency restrictions in medical aid-in-dying statutes—an issue relevant to at least nine states and the District of Columbia that currently limit such regimes to residents.

2. Summary of the Opinion

The Third Circuit affirms the District Court’s dismissal of Dr. Bryman’s constitutional challenge to New Jersey’s residency requirement in its Medical Aid in Dying Act.

Key holdings:

Standing and Justiciability: Although the out-of-state patient-plaintiffs died during the litigation, the case remains justiciable. As a regulated physician, Dr. Bryman has Article III standing to challenge the residency requirement and may assert the rights of his patients (third-party standing).
Privileges and Immunities (Article IV):
- The Clause protects only a limited set of historically recognized, “fundamental” privileges of citizenship, largely economic (working, accessing courts, holding property, etc.).
- Doctor-assisted suicide is not such a traditional privilege; indeed, there is a longstanding tradition against it, and fewer than a quarter of states allow it.
- Even if (a) interstate travel for medical care is a protected privilege (as Doe v. Bolton vaguely suggested), and (b) medical aid in dying counts as such care, New Jersey’s residency requirement still survives the applicable heightened scrutiny: the state has a substantial reason for the discrimination, and the means are substantially related to that reason.
Equal Protection: Residency classifications are not suspect. There is no fundamental right to assisted suicide (foreclosed by Glucksberg and Vacco), and the right to travel does not extend further than the Privileges and Immunities analysis. Thus, rational-basis review applies, and the residency requirement easily passes.
Dormant Commerce Clause: The residency requirement is not economic protectionism and is better analyzed under Privileges and Immunities. As in McBurney v. Young, the dormant Commerce Clause does not provide a remedy where the essential claim is that a state denies nonresidents a benefit conferred on its own citizens. No violation is found.

The court therefore upholds New Jersey’s power to confine medical aid in dying to its residents, emphasizing that the Constitution leaves this type of profound moral choice to the states.

3. Detailed Analysis

3.1 Factual and Procedural Background

New Jersey’s 2019 Act permits terminally ill patients (prognosis: six months or less) to obtain a prescription for lethal medication from a physician, which the patient must self-administer. To qualify, a patient must:

be a New Jersey resident,
make two oral requests and one written request,
be deemed mentally competent and acting voluntarily, and
comply with other procedural safeguards (waiting periods, documentation, etc.).

Physicians must verify residency (driver’s license, tax returns, voter registration) and are given immunity from New Jersey civil, criminal, and professional liability if they act in compliance with the Act. However, many neighboring states, including Pennsylvania, still criminalize assisted suicide. This creates a risk that a New Jersey physician who prescribes lethal medication to a nonresident who then ingests it at home could be prosecuted under that other state’s law.

Originally, the plaintiffs included:

Two terminally ill out-of-state patients (from Delaware and Pennsylvania) seeking access to New Jersey’s regime; and
Two New Jersey physicians who wished to provide medical aid in dying to such nonresident patients.

By the time of appeal:

Both patient-plaintiffs had died without obtaining medical aid in dying; and
One physician-plaintiff had retired.

Only Dr. Paul Bryman’s claim remained. The District Court dismissed the complaint, holding that:

assisted suicide is not a fundamental privilege or a fundamental right,
the law is not economic protectionism, and
the statute is constitutional under rational-basis review.

The Third Circuit reviews de novo and affirms.

3.2 Standing and Justiciability

3.2.1 Article III Standing of a Regulated Physician

The court first addresses whether the case remains live after the death of the patient-plaintiffs. Citing FDA v. Alliance for Hippocratic Medicine, 602 U.S. 367 (2024), the panel notes that government regulations that require or forbid conduct by a plaintiff typically satisfy:

Injury in fact – the regulated party faces a concrete burden or restriction; and
Causation – the injury is traceable to the challenged regulation.

That principle applies here: New Jersey law requires Dr. Bryman not to provide medical aid in dying to nonresidents. That legal constraint is a classic regulatory injury. The court draws further support from Washington v. Glucksberg, 521 U.S. 702 (1997), where physicians were allowed to challenge bans on assisted suicide. The combination of these cases confirms that:

physicians directly regulated by state medical-aid-in-dying laws have Article III standing to challenge those regulations.

3.2.2 Third-Party Standing (Asserting Patients’ Rights)

The court then turns to “prudential” third-party standing. Though the Supreme Court has not set bright-line rules, it frequently resolves third-party standing questions by analogy to prior cases (as noted in Alliance for Hippocratic Medicine and in Justice Alito’s concurrence in Trump v. CASA, Inc., 606 U.S. 831 (2025)).

Here, the panel points out:

Courts have previously allowed physicians to assert patients’ constitutional interests in access to contested medical procedures (e.g., assisted suicide in Glucksberg, abortion pre‑Dobbs).
Two terminally ill patients died during this very litigation, underscoring the practical impossibility of fully litigating these issues through patient-plaintiffs alone.

Drawing an analogy to Powers v. Ohio, 499 U.S. 400 (1991), where a criminal defendant could assert the equal protection rights of excluded jurors, the panel holds that:

the relationship between physician and patient, and
the obstacles to patients bringing and sustaining litigation (terminal illness and death),

justify allowing Dr. Bryman to raise his patients’ rights to travel and to access medical services. Thus, the case is justiciable despite the deaths of the original patients.

3.3 The Privileges and Immunities Clause (Article IV)

The heart of the opinion is the Article IV Privileges and Immunities analysis. The question: does New Jersey’s residency requirement abridge a fundamental privilege or immunity that the state must extend to out-of-state U.S. citizens?

3.3.1 Traditional Scope of the Clause

The Privileges and Immunities Clause of Article IV provides that:

“The Citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States.”

The Clause is not a broad equality principle. Instead, as Baldwin v. Fish & Game Commission of Montana, 436 U.S. 371, 388 (1978), and Corfield v. Coryell, 6 F. Cas. 546 (C.C.E.D. Pa. 1825), teach, it protects only a limited set of traditional, “fundamental” privileges—those “basic to the maintenance or well-being of the Union.”

Corfield famously listed examples:

the right to pursue a common calling (earn a living),
the right to acquire and hold property,
the right of access to the courts, and
the right to equal taxation.

The Supreme Court has applied the Clause mainly in economic contexts:

Toomer v. Witsell, 334 U.S. 385 (1948) – discriminatory commercial fishing license fees;
Hicklin v. Orbeck, 437 U.S. 518 (1978) – local hiring preferences; and
Supreme Court of New Hampshire v. Piper, 470 U.S. 274 (1985) – limiting bar admission to residents.

Conversely, the Court has declined to extend the Clause to:

recreational big-game hunting (Baldwin), and
access to state public-records statutes (McBurney v. Young, 569 U.S. 221 (2013)).

McBurney is especially instructive here: Virginia limited its state FOIA to Virginians, and the Supreme Court held that access to such records was not a traditional, fundamental privilege of citizenship. The Third Circuit analogizes medical aid in dying to FOIA access, rather than to core economic pursuits.

3.3.2 Doe v. Bolton and Its Weak Foundations After Dobbs

The plaintiffs’ centerpiece was Doe v. Bolton, 410 U.S. 179 (1973), the companion case to Roe v. Wade. On the same day that the Supreme Court recognized a federal right to abortion in Roe, it struck down various aspects of Georgia’s abortion law in Doe. In passing, Doe suggested that the Privileges and Immunities Clause protects persons who travel to other states for medical care, analogizing them to people entering a state to “ply their trade.”

The Third Circuit identifies several problems with relying on Doe:

Lack of a nonresident plaintiff: No out-of-state plaintiff was before the Court in Doe; thus its remarks on the Privileges and Immunities Clause were dicta rather than holdings.
Doctrinal dependence on Roe: Doe “rose together” with Roe, building on the newly announced substantive-due-process right to abortion. Once Dobbs v. Jackson Women’s Health Organization, 597 U.S. 215 (2022), overruled Roe, the doctrinal foundation of Doe largely crumbled.
Thin analysis: Even on its own terms, Doe’s discussion of interstate medical care under Article IV was cursory.

Post‑Dobbs, Doe’s Privileges and Immunities gloss stands “alone, if at all.” The Third Circuit therefore treats its statement about interstate medical care as at most weak persuasive authority.

The panel notes that Saenz v. Roe, 526 U.S. 489 (1999), cited Doe favorably in passing when describing the right to travel. To give plaintiffs the benefit of the doubt, the court assumes, arguendo, that travel for medical care might count as a protected privilege and that medical aid in dying could be framed as “general medical care.” But that assumption does not change the outcome, as explained below.

3.3.3 The Right to Travel and the “Welcome Visitor”

Saenz v. Roe famously identified three “strands” of the constitutional right to travel:

the right to enter and leave states,
the right to be treated as a “welcome visitor” in other states, and
the right to be treated like other citizens when becoming a new resident of another state.

Each strand has a different constitutional source. The second strand—the “welcome visitor” concept—is rooted in Article IV’s Privileges and Immunities Clause, and that is the strand plaintiffs invoke.

The key point: visitors need not receive every benefit states give their own citizens. They are entitled only to the historically recognized set of fundamental privileges. The Third Circuit is skeptical that “access to general medical care,” much less “physician-assisted suicide,” falls within that narrow set.

3.3.4 No Traditional Privilege to Physician-Assisted Suicide

The court then applies a history-and-tradition approach, paralleling Glucksberg. There is a long legal and cultural tradition against assisted suicide. Many states still criminalize it outright, without medical exceptions. Only eleven jurisdictions (ten states plus D.C., with an eleventh state on the way) have recently legalized it, and most impose strict safeguards and residency restrictions.

Invoking Glucksberg, which rejected a fundamental Fourteenth Amendment right to assisted suicide, the court reasons:

If assisted suicide is not a fundamental “right” for substantive due process, it cannot plausibly be a traditional privilege of citizenship under Article IV, especially given its very recent, limited recognition in only a minority of states.

Quoting McBurney, the court describes medical aid in dying as “of relatively recent vintage” and notes that it has not “at all times been enjoyed by the citizens of the several states,” as Corfield requires for a protected privilege.

Thus:

There is no Article IV obligation to extend medical aid in dying to nonresidents.

3.3.5 Even If Interstate Medical Care Is a Protected Privilege, the Statute Survives

Assuming for the sake of argument that:

(1) interstate travel for “medical care” is a protected privilege under Article IV, and
(2) New Jersey’s medical aid in dying regime counts as “medical care” within that privilege,

New Jersey’s residency requirement must still be tested under the Toomer/Piper framework.

Under that framework, when a law burdens a fundamental privilege, the state must show:

a substantial reason for different treatment of nonresidents (i.e., nonresidents are a “peculiar source of the evil” the statute targets); and
a substantial relationship between the discriminatory means (the residency requirement) and the state’s objectives.

Importantly, the standard does not demand the least restrictive means or a perfect fit; a “substantial relationship” suffices.

3.3.6 New Jersey’s Justifications: Protection of Doctors, Patients, and Interstate Harmony

At the motion-to-dismiss stage, it is somewhat unusual to engage in this kind of means–ends review. But the court underscores that it is dealing with legislative facts and finds the record sufficient for such analysis.

New Jersey articulates three primary justifications for limiting medical aid in dying to residents:

Protecting physicians from out-of-state criminal and civil liability.

New Jersey can immunize physicians from liability under New Jersey law, but it cannot shield them from prosecution or lawsuits under other states’ laws. Many states still criminalize assisted suicide, and some assert extraterritorial jurisdiction over certain criminal acts.

For example, Pennsylvania makes assisting suicide a crime and claims jurisdiction based on either conduct or results occurring within the state. If a New Jersey doctor prescribes lethal medication to a Pennsylvanian who ingests the medication in Pennsylvania, prosecutors might reasonably assert jurisdiction over the physician.

The residency rule thus serves to:
- keep both patients and pills in New Jersey, and
- minimize realistic risks of extraterritorial prosecution of New Jersey physicians.
Preserving interstate comity and avoiding friction with other states.

New Jersey has made a policy choice to permit medical aid in dying, but many states have chosen the opposite path. Allowing nonresidents to travel in, obtain lethal prescriptions, and take those medications back home could be seen as undermining those states’ criminal and moral frameworks.

By limiting eligibility to residents, New Jersey:
- confines the effects of its policy within its own borders, and
- reduces the risk of interstate conflicts in an area the court calls “morally fraught.”
The court ties this to the constitutional goal of “domestic Tranquility,” emphasizing the federalism interest in allowing morally diverse state policies without provoking inter-state clashes.
Protecting patients from coercion and undue influence, especially via insurance and contract arrangements.

The Act prohibits provisions in contracts, wills, and insurance policies that might pressure terminally ill patients to follow through once they initiate the process. This is designed to protect vulnerable patients from financial or familial coercion.

Crucially, New Jersey’s regulatory reach is strongest within its own borders and over its own residents. It cannot easily regulate:
- insurance policies drafted and governed under other states’ laws, or
- malpractice and other civil claims arising under other states’ legal regimes.
Decisions like Ginsberg v. Quest Diagnostics (N.J. App. Div. 2015) and Viking Pump, Inc. v. Century Indemnity Co. (Del. Ch. 2009) underscore that the law of the state most closely tied to the relationship—often the place of licensure or the state of the insurance contract—will govern. That makes New Jersey’s ability to protect nonresident patients more limited and uncertain.

The court also notes, without fully developing, additional possible justifications (e.g., mental-health evaluations conducted by local providers, as contemplated in the Act and referenced in Glucksberg).

3.3.7 Satisfying the “Substantial Reason” and “Substantial Relationship” Tests

Taken together, these justifications persuade the court that:

nonresidents are indeed a peculiar source of the risks that the legislature might reasonably perceive—particularly extraterritorial liability, lack of effective regulatory control over insurance and malpractice, and interstate friction;
the residency requirement is substantially related to those goals, even if it is not the least restrictive conceivable approach.

The court explicitly rejects the notion that Article IV demands perfect tailoring; it requires only a substantial fit between means and ends. The residency requirement satisfies that standard.

Thus, even under an elevated level of scrutiny, the Privileges and Immunities challenge fails.

3.4 Equal Protection

The Equal Protection Clause analysis largely tracks the Privileges and Immunities discussion.

Residency classifications are not inherently suspect; they do not, by themselves, trigger strict scrutiny.
Elevated scrutiny would apply only if the classification burdens a fundamental right.

The plaintiff asserts:

a right to physician-assisted suicide; and
a right to interstate travel.

Both arguments fail:

No fundamental right to assisted suicide.

Glucksberg explicitly held that there is no fundamental liberty interest in physician-assisted suicide under the Due Process Clause. Vacco v. Quill, 521 U.S. 793 (1997), likewise rejected equal-protection attacks on bans on assisted suicide. The Third Circuit notes that plaintiffs acknowledge this and do not seriously attempt to relitigate.
Right to travel extends only as far as the “welcome visitor” privilege already analyzed.

Under Saenz, the right to travel for visitors is coextensive with Article IV’s Privileges and Immunities protection. Because the court has already concluded that no protected privilege is violated—or, in the alternative, that any infringement is constitutionally justified—there is no independent Equal Protection violation based on the right to travel.

Accordingly, the statute is reviewed under rational-basis scrutiny. The interests already identified—protecting physicians, avoiding interstate friction, shielding patients from coercive insurance and contractual structures, and preventing rash decisions under conditions of pain or depression—are all legitimate governmental interests, and the residency requirement is rationally related to them.

The Equal Protection claim therefore fails.

3.5 Dormant Commerce Clause

The dormant Commerce Clause doctrine prohibits states from engaging in economic protectionism or placing undue burdens on interstate commerce in the absence of congressional authorization.

The doctrine recognizes two main categories of problematic state laws:

Facially discriminatory or protectionist laws – those that explicitly favor in-state economic actors or block out-of-state goods and services. Such laws are subject to “virtually per se invalidity” and must be narrowly tailored to serve a legitimate local purpose with no adequate nondiscriminatory alternatives (Granholm v. Heald, Hughes v. Oklahoma, Tennessee Wine & Spirits, Dean Milk).
Facially neutral laws that unduly burden interstate commerce – subject to Pike balancing, which weighs the burdens on interstate commerce against the putative local benefits, invalidating laws only where the burden is clearly excessive in relation to local benefits.

The Third Circuit, however, largely sidesteps these tiers because it sees the case as non-economic at its core:

The statute is characterized as moral and health-safety regulation, not an economic measure aimed at “building up domestic commerce” at the expense of out-of-state businesses.
The core grievance is that nonresidents are denied a state-conferred benefit (access to medical aid in dying) that residents enjoy—an issue that is doctrinally located in Privileges and Immunities, not in the Commerce Clause.

Invoking McBurney, 569 U.S. 221, the court notes that the dormant Commerce Clause:

“cannot remedy these types of claims” where the essence of the complaint is equal treatment of residents and nonresidents for state-provided services.

Accordingly:

No heightened scrutiny or Pike balancing is necessary.
The dormant Commerce Clause claim fails at the threshold because the statute is not aimed at economic protectionism and does not distort an interstate market in goods or services in the relevant sense.

4. Complex Concepts Simplified

4.1 Article IV Privileges and Immunities vs. Fourteenth Amendment Rights

It is easy to confuse:

Article IV’s Privileges and Immunities Clause (interstate equality among citizens of different states), and
the Fourteenth Amendment’s Due Process and Equal Protection Clauses (limits on state power over all persons, including their own citizens).

In this case:

Article IV is about whether New Jersey can treat nonresidents differently from its own residents with respect to certain fundamental privileges of state citizenship.
Substantive Due Process (via Glucksberg) asks whether there is a fundamental right to assisted suicide for anyone, resident or not. The answer is no.

Thus, even if New Jersey could ban medical aid in dying altogether, it has nonetheless chosen to legalize it for its own residents. Article IV only asks whether it must extend that policy to nonresidents. The court says no.

4.2 The Right to Travel: Three Components

The “right to travel” is not a single, free-floating right; as Saenz explains, it encompasses:

Free ingress and egress – you can cross state lines without being blocked.
Equality as a visitor – while you are temporarily in another state, you are entitled to certain basic privileges of citizenship (Article IV).
Equality as a new resident – if you move to a new state, that state cannot indefinitely treat you worse than long-term residents (Fourteenth Amendment).

This case involves only the second component—whether nonresidents must be treated as “welcome visitors” with respect to New Jersey’s medical-aid-in-dying regime.

4.3 Rational-Basis Review in Equal Protection

Under rational-basis review, a law is unconstitutional only if:

the state lacks any legitimate interest in the policy, or
there is no rational relationship between the law and any conceivable legitimate interest.

This is highly deferential. Courts typically uphold laws under rational basis so long as any plausible rational justification can be imagined, even if the law is imperfect, overinclusive, or underinclusive. Because assisted suicide is not a fundamental right and residency is not a suspect classification, the Act easily passes this test.

4.4 The Dormant Commerce Clause in Plain Terms

The dormant Commerce Clause is essentially a negative implication of the Commerce Clause:

Because Congress has power to regulate interstate commerce, individual states may not enact laws that unduly interfere with or discriminate against interstate trade in goods and services when Congress has not authorized them to do so.

But not every law that has cross-border effects is unconstitutional. Classic examples of violations are:

laws that ban or heavily burden the import or export of goods (e.g., forbidding import of out-of-state waste), or
laws that expressly favor in-state producers over out-of-state competitors.

Here, New Jersey’s law does not favor New Jersey doctors over out-of-state doctors in some economic market; it regulates who may be a patient in a sensitive medical regime. The Third Circuit views this primarily as a moral/health policy choice rather than a commercial regulation directed at market competition.

4.5 Third-Party Standing

“Standing” normally requires that the person bringing the lawsuit be the one whose rights are directly violated. But in some situations, courts allow “third-party standing” when:

there is a close relationship between the plaintiff and the third party, and

the third party faces a serious obstacle to suing on their own behalf.

Examples include:

doctors asserting the rights of their patients, and
criminal defendants asserting the rights of excluded jurors (Powers v. Ohio).

Here, terminally ill patients may die before their case can be fully litigated. The court finds this to be a serious obstacle, justifying the physician’s ability to raise their constitutional interests.

5. Impact and Broader Significance

5.1 Direct Effects on Medical Aid-in-Dying Regimes

Substantively, the decision:

affirms that New Jersey may limit access to medical aid in dying to residents;
provides a detailed constitutional roadmap for other states with similar residency requirements (which, according to the opinion, include nine of the eleven medical-aid-in-dying jurisdictions plus D.C.).

Those states can now point to:

Glucksberg (no fundamental right to assisted suicide),
Corfield and McBurney (narrow scope of Article IV privileges), and
Bryman (substantial-reason justification for residency limitations in this context)

as grounds to defend their laws against similar Article IV, Equal Protection, and dormant Commerce Clause challenges.

5.2 The Status of Doe v. Bolton and the Post-Dobbs Landscape

Second, the opinion is an important post‑Dobbs signal regarding Doe v. Bolton. Although the Supreme Court has not expressly overruled Doe, this decision:

treats Doe’s Privileges and Immunities discussion as dicta that is now doctrinally unstable;
carefully avoids relying on Doe to expand Article IV protections; and
suggests that Saenz’s later reference to Doe is insufficient to give the latter strong precedential force in other contexts.

For future litigation involving travel for abortion, gender-affirming care, or other controversial procedures, Bryman signals that lower courts may be reluctant to treat Doe as a robust source of Privileges and Immunities protections for interstate medical travel.

5.3 Federalism and Morally Contested Health Policies

The opinion also underscores a broader theme: federal courts should be cautious in constitutionalizing access to morally and ethically contested medical practices, leaving such policy choices to state legislatures.

The court repeatedly emphasizes:

the moral gravity of physician-assisted suicide,
the diversity of states’ approaches, and
the role of the Constitution in allowing, not resolving, these differences.

This reinforces:

the Glucksberg/Dobbs commitment to historical analysis for recognizing new fundamental rights, and
a strong federalism-based deference to states in setting health and safety policy.

5.4 Privileges and Immunities vs. Dormant Commerce Clause as Doctrinal Channels

Finally, the opinion continues the trend—exemplified by McBurney—of:

channeling complaints about unequal access to state benefits for nonresidents into the Privileges and Immunities framework, and
reserving the dormant Commerce Clause for cases of economic protectionism and market distortion.

This doctrinal housekeeping matters for future cases involving:

state-specific benefits (e.g., tuition, public assistance, specialized health programs), and
residency-based eligibility for various publicly regulated services.

Litigants attempting to challenge residency limitations in non-economic contexts may find the dormant Commerce Clause increasingly inhospitable; they must instead rely on the more historically constrained Privileges and Immunities doctrine.

6. Conclusion

Dr. Paul Bryman v. Phil Murphy solidifies the constitutional footing of state residency restrictions in medical aid-in-dying regimes and clarifies the limited role of the U.S. Constitution in arbitrating deeply contested moral questions surrounding end-of-life choices.

The decision holds that:

physician-assisted suicide is not a traditional, fundamental privilege of state citizenship protected for visitors under Article IV;
even if interstate travel for medical care is a protected privilege, New Jersey has substantial, well-tailored reasons—protection of physicians, patients, and interstate comity—to limit medical aid in dying to its residents;
no independent Equal Protection or dormant Commerce Clause violation arises from such a residency classification.

More broadly, the opinion is a careful exercise in constitutional restraint. It respects state experimentation in morally fraught fields, follows the Supreme Court’s historical-tradition approach to defining protected rights and privileges, and properly allocates doctrinal challenges between Article IV and the dormant Commerce Clause. For jurisdictions grappling with similar issues—whether in assisted suicide, abortion, or other contentious areas—Bryman will be a significant and detailed point of reference.