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In re Quinlan

Supreme Court of New Jersey

January 26, 1976, Argued ; March 31, 1976, Decided

No Number in Original

Opinion

 [*18]  [**651]   THE LITIGATION 

The central figure in this tragic case is Karen Ann Quinlan, a New Jersey resident. At the age of 22, she lies in a debilitated and allegedly moribund state at Saint Clare's Hospital in Denville, New Jersey. The litigation has to do, in final analysis, with her life, -- its continuance or cessation, -- and the responsibilities, rights and duties, with regard to any fateful decision concerning it, of her family, her guardian, her doctors, the hospital, the State through its law enforcement authorities, and finally the courts of justice.

The issues are before this Court following its direct certification of the action under the rule, R. 2:12-1, prior to hearing in the Superior Court, Appellate Division, to which the appellant (hereafter "plaintiff") Joseph Quinlan, Karen's father, had appealed the adverse judgment of the Chancery Division.

Due to extensive physical damage fully described in the able opinion of the trial [***3]  judge, Judge Muir, supporting that judgment, Karen allegedly was incompetent. Joseph Quinlan sought the adjudication of that incompetency. He wished to be appointed guardian of the person and property of his daughter. It was proposed by him that such letters of guardianship, if granted, should contain an express power to him as guardian to authorize the discontinuance of all extraordinary medical procedures now allegedly sustaining Karen's vital processes and hence her life, since these measures, he asserted, present no hope of her eventual recovery. A guardian ad litem was appointed by Judge Muir to represent the interest of the alleged incompetent.

By a supplemental complaint, in view of the extraordinary nature of the relief sought by plaintiff and the involvement therein of their several rights and responsibilities, other parties were added. These included the treating physicians and the hospital, the relief sought being that they be restrained from interfering with the carrying out of any such extraordinary  [*19]  authorization in the event it were to be granted by the court. Joined, as well, was the Prosecutor of Morris County (he being charged with responsibility [***4]  for enforcement of the criminal law), to enjoin him from interfering with, or projecting a criminal prosecution which otherwise might ensue in the event of, cessation of life in Karen resulting from the exercise of such extraordinary authorization were it to be granted to the guardian.

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70 N.J. 10 *; 355 A.2d 647 **; 1976 N.J. LEXIS 181 ***; 79 A.L.R.3d 205

IN THE MATTER OF KAREN QUINLAN, AN ALLEGED INCOMPETENT

CORE TERMS

patient, respirator, circumstances, terminate, rights, brain, vegetative, religious, ethical, right to privacy, guardianship, incompetent, daughter, courts, irreversible, technology, cruel and unusual punishment, appointed, cases, medical practice, medical standard, authorization, cognitive, decisions, sapient, prolongation, resuscitate, judgments, comatose, measures

Constitutional Law, Bill of Rights, Fundamental Freedoms, General Overview, Governments, State & Territorial Governments, Freedom of Religion, Civil Procedure, Preliminary Considerations, Justiciability, The Judiciary, Case or Controversy, Advisory Opinions, Standing, Declaratory Judgments, State Declaratory Judgments, Judgments, Relief From Judgments, Free Exercise of Religion, Fundamental Rights, Cruel & Unusual Punishment, Criminal Law & Procedure, Sentencing, Substantive Due Process, Privacy, Personal Decisions, Healthcare Law, Medical Treatment, Patient Confidentiality, Unenumerated Rights, End-of-Life Decisions, Abortion, Right to Privacy, Parties, Pro Se Litigants, Right to Self Representation, Equity, Torts, Standards of Care, Special Care, Highly Skilled Professionals, Courts, Judges, Criminal Offenses, Homicide, Manslaughter & Murder, Assisted Suicide, Elements, Common Law, Inchoate Crimes, Family Law, Guardians