Washington v. Glucksberg

Facts

Washington made it a felony to knowingly cause or aid another person to attempt suicide. The crime carried up to five years’ imprisonment and up to a $10,000 fine. Assisting a suicide had been a crime in Washington since its first Territorial Legislature acted in 1854. Washington’s Natural Death Act, enacted in 1979, separately provided that withholding or withdrawing life-sustaining treatment at a patient’s direction is not a suicide. The respondents were four Washington physicians, Glucksberg, Halperin, Preston and Shalit. They occasionally treated terminally ill, suffering patients and said they would help those patients end their lives if not for the ban. In January 1994 the doctors sued in federal district court, together with three gravely ill plaintiffs who used pseudonyms and have since died, and Compassion in Dying, a nonprofit group that counsels people considering physician-assisted suicide. They asked for a declaration that the statute was unconstitutional on its face. They claimed a liberty interest protected by the Fourteenth Amendment that reaches a mentally competent, terminally ill adult’s personal choice to commit physician-assisted suicide. The petitioners were the State of Washington and its Attorney General.

Issues

1. Does the Due Process Clause of the Fourteenth Amendment protect, as a fundamental liberty, a right to commit suicide that includes a right to assistance in doing so?
2. If it does not, does Washington’s ban on causing or aiding a suicide still bear a rational relation to legitimate government interests, so that it is valid on its face and as applied to competent, terminally ill adults who wish to hasten their deaths by obtaining medication prescribed by their doctors?

Holding

The asserted right to assistance in committing suicide is not a fundamental liberty interest protected by the Due Process Clause. Washington’s ban is rationally related to legitimate state interests, so it does not violate the Fourteenth Amendment, on its face or as applied to competent, terminally ill adults who wish to hasten their deaths by obtaining medication prescribed by their doctors.