In The Matter Of Karen Quinlan, An Alleged Incompetent
355 A.2d 647 (1976)
Issues
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Nature Of The Case
This section contains the nature of the case and procedural background.
Facts
For reasons still unclear, Karen Quinlan ceased breathing for at least two 15-minute periods. She received some ineffectual mouth-to-mouth resuscitation from friends. She was taken by ambulance to Newton Memorial Hospital. She had a temperature of 100 degrees, her pupils were unreactive and she was unresponsive even to deep pain. The history at the time of her admission to that hospital was essentially incomplete and uninformative. Three days later, Dr. Morse found her comatose with evidence of decortication, a condition relating to derangement of the cortex of the brain causing a physical posture in which the upper extremities are flexed and the lower extremities are extended. She required a respirator. With limited and incomplete information, Dr. Morse concluded that a prolonged lack of oxygen in the bloodstream, anoxia, was identified with her condition as he saw it upon first observation. When she was later transferred to Saint Clare's Hospital she was still unconscious, still on a respirator and a tracheotomy had been performed. Dr. Morse conducted extensive and detailed examinations. An electroencephalogram (EEG) measuring the electrical rhythm of the brain was performed and Dr. Morse characterized the result as 'abnormal but it showed some activity and was consistent with her clinical state.' A brain scan, an angiogram, and a lumbar puncture were normal. Dr. Morse testified that Karen has been in a state of coma, and lack of consciousness, since he began treating her. He explained that there are basically two types of coma, sleep-like unresponsiveness and awake unresponsiveness. Karen was originally in a sleep-like unresponsive condition but soon developed 'sleep-wake' cycles, apparently a normal improvement for comatose patients occurring within three to four weeks. In the awake cycle, she blinks, cries out, and does things of that sort but is still totally unaware of anyone or anything around her. A number of expert doctors who examined her characterized Karen as being in a 'chronic persistent vegetative state.' Karen no longer had any cognitive function but all the experts believed she was not brain dead. Dr. Plum testified that brain death necessarily must mean the death of both the vegetative and the sapient functions of the brain. Therefore, the presence of any function that is regulated or governed or controlled by the deeper parts of the brain which in layman's terms might be considered purely vegetative would mean that the brain is not biologically dead. Attempts to 'wean' Karen from the respirator were unsuccessful and have been abandoned. The experts believe that Karen cannot now survive without the assistance of the respirator; that exactly how long she would live without it is unknown; that the strong likelihood is that death would follow soon after its removal, and that removal would also risk further brain damage and would curtail the assistance the respirator presently provides in warding off infection. The consensus not only of the treating physicians but also of the several qualified experts who testified in the case, the removal from the respirator would not conform to medical practices, standards, and traditions. The further medical consensus was that Karen in addition to being comatose is in a chronic and persistent 'vegetative' state, having no awareness of anything or anyone around her and existing at a primitive reflex level. Although she does have some brain stem function (ineffective for respiration) and has other reactions one normally associates with being alive, such as moving, reacting to light, sound, and noxious stimuli, blinking her eyes, and the like, the quality of her feeling impulses is unknown. She grimaces, makes sterotyped cries and sounds, and has chewing motions. Her blood pressure is normal. Karen remains in the intensive care unit receiving 24-hour care by a team of four nurses characterized, as was the medical attention, as 'excellent.' She is nourished by feeding by way of a nasal-gastro tube and is routinely examined for infection, which under these circumstances is a serious life threat. The result is that her condition is considered remarkable under the unhappy circumstances involved. Karen has suffered a weight loss of at least 40 pounds, and undergoing a continuing deteriorative process. Her posture is fetal-like and grotesque; there is extreme flexion-rigidity of the arms, legs, and related muscles and her joints are severely rigid and deformed. Karen is in a chronic and persistent vegetative state. No form of treatment which can cure or improve that condition is known or available. She can never be restored to a cognitive or sapient life. Her overall prognosis is extremely poor. P and his family, finally reconciled to the certainty of Karen's impending death, requested the withdrawal of life support mechanisms. P consulted with his parish priest and later with the Catholic chaplain of Saint Clare's Hospital. He would not, he testified, have sought termination if that act were to be morally wrong or in conflict with the tenets of the religion he so profoundly respects. The Church sided with P. Ds opposed P’s decision because under modern medical standards, Karen was not dead. The court agreed with Ds and P appealed.
Holding & Decision
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Legal Analysis
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