People v. Kevorkian

447 Mich. 436, 527 N.W.2d 714 (1994)



Three kinds of challenges may be brought against statutes on the basis of Mich. Const. art 4, § 24: (1) a "title-body" challenge, (2) a multiple-object challenge, and (3) a change of purpose challenge.


Michigan created an assisted suicide statute imposing criminal responsibility on persons who assist others in committing suicide. The constitutionality of this statute was questioned. In one case, a man was convicted of murder for assisting in the suicide of another. The Court of Appeals' determined that the assisted suicide statute was enacted in violation of Mich. Const. 1963, art. IV, § 24. The case was appealed.


Was the Michigan assisted suicide statute constitutional?




The court held (1) the assisted suicide statute embraced only one object and was thus validly enacted, (2) the statute was not enacted in violation of the Change in Purpose clause of the state constitution, (3) the United States Supreme Court would not find a liberty interest in suicide, let alone assisted suicide, that was protected by the Due Process Clause of U.S. Const. amend. XIV, (4) the principles that guided the analysis of substantive due process did not support the recognition of a right to commit suicide, (5) it was incorrect to conclude on the basis of the absence of criminal penalties for an act of suicide itself that there was a constitutional right to commit suicide, (6) there was no fundamental right to commit suicide that was protected by the Due Process Clause.

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