In re Quinlan, 70 N.J. 10, 355 A.2d 647 (N.J. 1976), cert. denied, 429 U.S. 922 (1976)
In re Quinlan is the seminal American case on end-of-life decision-making and the constitutional and common-law contours of a patient's right to refuse life-sustaining treatment. Decided by the New Jersey Supreme Court in 1976, it arose after 21-year-old Karen Ann Quinlan suffered catastrophic anoxic brain injury and was maintained on a mechanical ventilator.
Does an incompetent patient, through a guardian, have a constitutional and common-law right to discontinue extraordinary life-sustaining treatment (a mechanical respirator), and if so, under what standards and procedures may that right be exercised without incurring civil or criminal liability?
An incompetent patient retains a right of privacy that encompasses the refusal of extraordinary life-sustaining medical treatment. That right may be asserted by a duly appointed guardian under a substituted judgment approach when the medical evidence establishes no reasonable possibility of the patient regaining cognitive, sapient life. When the guardian's decision concurs with the attending physicians and is reviewed and approved by a hospital ethics committee or comparable institutional body, withdrawal of extraordinary life support is lawful and does not subject participating physicians or the hospital to civil or criminal liability, as the patient's underlying condition—not the act of withdrawal—is deemed the proximate cause of death. The State's interests in preserving life, preventing suicide, protecting third parties, and maintaining medical ethics diminish as the prognosis for recovery wanes and must, in appropriate cases, yield to the patient's privacy right.
Reversing the trial court in relevant part, the New Jersey Supreme Court held that Karen Ann Quinlan's constitutional right of privacy permitted the discontinuation of her respirator upon the substituted judgment of her guardian-father, provided that the attending physicians and a hospital ethics committee concurred that there was no reasonable possibility she would return to a cognitive, sapient state. The Court further held that physicians and the hospital acting in accordance with this procedure would not incur civil or criminal liability.
Quinlan is the foundational U.S. case recognizing that the right to refuse life-sustaining treatment extends to incompetent patients through surrogates. It operationalized that right with the now-familiar concepts of substituted judgment, medical futility, and ethics committee review, and it normalized end-of-life deliberation within hospitals. The decision catalyzed the spread of hospital ethics committees and influenced state legislation on living wills and advance directives, ultimately shaping federal policy through the Patient Self-Determination Act of 1990. For law students, Quinlan frames the doctrinal balance between individual autonomy and the State's interests, introduces analytic tools for surrogate decision-making, and sets the stage for later cases—In re Conroy (artificial nutrition and hydration) and Cruzan (clear-and-convincing-evidence standard)—that refined the evidentiary and procedural contours of end-of-life law.