Washington v. Glucksberg Case Analysis Essay

Introduction

Washington State legislated that it is an offense to offer assistance to a person intending to commit suicide. The law applies when a person knowingly attempts or helps another person to end his or her life. The case involves four physicians from the state of Washington who were involved with treatment and care for terminally ill patients and a humanitarian organization that specialized in advising such patients (US, 1997). The organization was a non-profit entity, and part of their business was counseling suffering patients on how they would go about their lives. The counseling involved the decision whether to commit suicide or engage in activities such as euthanasia to end the suffering. The case also involved three patients who suffered from terminal illnesses. The grounds for the case was that the respondents challenged the state of Washington in seeking to declare the law as unconstitutional and permitting physician-assisted suicide.

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Procedural History

Physicians, patients and a non-profit organizational sought to prove that the state of Washington's ban on assisted suicide was not facially constitutional (King, 2000). The state's court upheld the ban on assisting suicide and argued that the right to live or die is a "liberty interest" protected by the U.S. Constitution.

Case Facts

The state of Washington had enacted two major statutes that were the foundation of the case. The first statute barred anyone from providing help to another individual to end his or her life. The second statute held that the decisions and actions of a doctor aimed at sustaining the life of a patient could not be considered as assisting in suicide (King, 2000). The doctors were in constant engagement with the terminally ill patients and wanted to help them end their lives. The patients had been treated to all available medical procedures to manage their terminal illnesses and had reached a point where they could not take it anymore. The doctors admitted that with consideration of the ethics of the medical field that it would be acceptable to assist the patients to end their suffering. The patients and the non-profit organization were of the view that the doctors assist the patients in ending their lives and escaping the terminal damnation caused by illnesses. The doctors were aware of the state of Washington statutes and sought to challenge the law to legalize their actions.

The district court rendered the statute on assisting suicide as invalid, but the court of appeal reversed it. However, the court of appeal later affirmed the district in an en banc act of reversing itself (US, 1997). The affirmation of the en banc decision was founded on the legal clause that the United States constitution acknowledges the liberty interest of life and the control of when one dies. The attorney general of the state of Washington referred to the liberty interests that were protected by the "Fourteenth Amendment Due Process Clause" that extended the choice to commit medically assisted suicide to patients of terminal illnesses. The clause only applies if the terminally ill patient is of competent mind and is aware of the decisions and their consequences. The decision by the district court to declare the statute unconstitutional was founded on two previous cases. The two cases are the "Cruzan v. Director, Mo. Dept. of Health, 497 U. S. 261" and "Planned Parenthood of Southeastern Pa. v. Casey, 505 U. S. 833". The Anglo-American law has disapproved aiding people to commit suicide for more than seven decades. Assisting suicide is a crime in virtually all American states, and there has never been a recorded exception to the crime to permit those who were in near-death situations.

Issues

The case raised two major issues. The first issue is whether the prohibition of suicide by Washington State offended the "Fourteenth Amendment Due Process Clause" (US, 1997). The other issue was whether the constitutionally protected liberty interests included the right to perform suicide and due to the confidence of the first preposition the fortiori right to receive assistance in committing suicide.

Holding

The right to engage in assisted suicide does not count as a liberty interest in the United States Constitution. The same is also not acknowledge in the common laws of the land that have governed America since the advent of human civilization. The state of Washington law must therefore only relate to the legally binding interests of the state.

Ruling and Reasoning

William Hubbs Rehnquist, the 16th Chief Justice of the U.S. reversed the Ninth Circuit Ruling, which had argued that the Washington ban violated the "Fourteenth Amendment Due Process Clause." Assisting a person in ending his or her life was not a constitutionally recognized interest and thus would not receive protection from the "Due Process Clause" (US, 1997). The decision also referred to the "Moore v. East Cleveland," which defined liberty interests as human practices that had deep presence and acceptance in the history of a nation. Justice Rehnquist acknowledged that assisting suicide victims had been disregarded for many years on American soil and many states had attempted reversing the ban with similar results. The early common law of the English culture had harsh penalties to the culprits found guilty of assisting suicide. The chief justice employed the decisions made in the "Planned Parenthood v. Casey and Roe v. Wade case." In both the aforementioned cases, English Common Law was employed in the determination of the processes that qualify to be legal in contemporary America and protected by the constitution as liberty interests. The ruling was further inspired by the "Heller v. Doe, 509 U.S. 312, 319-320" which stated protection of human life is paramount in any society and the Washington ban prevented intentional killing thus working in line with the public health goal of preventing suicide.

Concurring Opinions

Chief Justice Hubbs Rehnquist delivered the ruling and Justice Thomas O'Connor, JJ, Kennedy, Scalia, Ginsburg, and Breyer joined his ruling. The aforementioned were all justices at the time. Justices Ginsburg and Breyer filed opinions that concurred with the judgment (King, 2000). The court of appeal felt that the Washington state ban on assisted suicide was rational and in line with the liberty interests of preserving human life. The ban protects terminally ill patients and patients of impaired cognitions from coercion and malpractices in Medicare. The ban also prevented patients from being abused due to their medical conditions by friends and family members of ill will who may subject them to assisted suicide in a bid to achieve financial and other egocentric gains. Declaring assisted suicide as an act protected by the U.S constitutional would be like a death penalty to terminally ill patients because most of them eventually lose hope in Medicare and would opt for the assisted suicide. Lifting the ban would open up the state to condemning terminally ill patients, and cases of involuntary euthanasia would increase.

References

King, P. (2000). Washington v. Glucksberg: Influence of the Court in Care of the Terminally Illand Physician Assisted Suicide. JL & Health, 15, 271.

US, S. C. (1997). Washington v. Glucksberg. West's Supreme Court reporter, 117, 2258.