Oregon passed the Death
With Dignity Act, which allowed
doctors to prescribe lethal drugs to terminally ill patients.
In order to stop the Act, the
US Attorney General (Ashcroft, later Gonzales) issued an interpretive
rule saying that physician-assisted
suicide violated the Federal Controlled Substances Act (CSA), and would result in revocation of the
doctor's license.
The Attorney General felt
that he could overrule State law on this issue.
Oregon sued for an injunction
to block the interpretive rule.
The Trial Court found for
Oregon. The Department of Justice (DOJ) appealed.
The Trial Court found that
DOJ did not have the authority under the CSA to regulate physician-assisted suicide.
Basically, the CSA had to do with illegal drugs, not with
medial decisions. The plain language of the Stature
didn't allow the Attorney General's action.
Medical decisions were a
matter the courts had traditionally left up to the States. (aka
Federalism).
See Linder v. United
States (268 U.S. 5 (1925)).
DOJ unsuccessfully argued
that the courts are to give judicial deference to Agency decisions, and
therefore the Court had no authority to overturn their ruling.
The Appellate Court affirmed.
DOJ appealed.
The US Supreme Court affirmed.
The US Supreme Court found
that Congress' intent was clear and that the purpose of the CSA was to regulate criminal activity and illegal
drugs.
Under the standard
established by Chevron U.S.A. Inc. v. Natural Resources Defense
Council (467 U.S. 837 (1984)), when
Congress' intent is clear, there is no room for Agency interpretation of
the Statute.
Therefore, based on the Chevron
Doctrine, the courts do not have to
give judicial deference to DOJ's decision.
The Court noted that he
Federal government does theoretically have the power to limit access to
drugs for medical purposes, but the CSA itself did not grant the authority for DOJ to ban suicide drugs.
In a dissent it was argued
that suicide drugs are not a "legitimate medical purpose" and
therefore are excluded from the traditional deference to the States on
medical matters.
In addition, the Court had
just recently said that the CSA
did allow DOJ to ban the use of marijuana for medical purposes (See Gonzales
v. Raich (545 U.S. 1 (2005)), so how
could that be considered consistent with this ruling?
