Washington State had a
prohibition on assisted suicide as part of their criminal code (Wash.
Rev. Code §9A.36.060(1)). A ballot
initiative tried to overturn the law, but it failed.
A similar ballot initiative
in Oregon passed.
A number of terminally ill
people in Washington, including Glucksberg, sued for a declaratory
judgment against the law.
Glucksberg argued that the
law violated the Due Process Clause
of the 14th Amendment.
Glucksberg pointed to the
decision in Cruzan v. Missouri Dept. of Health (497 U.S. 261 (1989)), which said that
terminally ill people had a right to refuse medical treatment.
Glucksberg pointed the
decision in Planned Parenthood v. Casey (505 U.S. 833 (1992)), which said that the Due Process Clause
includes basic and intimate exercises of personal automony.
The Trial Court granted the
judgment. Washington appealed.
The Appellate Court affirmed.
Washington appealed.
The US Supreme Court reversed.
The US Supreme Court found that
Washington's ban on assisted suicide was not a violation of the 14th
Amendment, and that there is no
fundamental liberty interest protected by the Due Process Clause.
The Court found that just
because many of the rights and liberties protected by the Due Process
Clause revolve around personal
autonomy does not warrant the sweeping conclusion that any and all
important, intimate, and personal decisions are so protected.
The Court found that in
order to be constitutional, Washington's ban had to be rationally related
to legitimate government interests. In this, the Court found that it
was, because Washington has an interest in:
The public health problem
of suicide.
The integrity and ethics of
the medical profession.
The protection of
vulnerable groups (such as the poor and elderly) from abuse, neglect,
and mistakes.
Preventing a 'slippery
slope' toward legalizing euthanasia.
