Quill v. Vacco

80 F.3d 716 (2d Cir. 1996)



While rational basis scrutiny governs judicial review of the constitutionality of legislation in the areas of social welfare and economics, strict scrutiny is the standard of review where a classification impermissibly interferes with the exercise of a fundamental right or operates to the peculiar disadvantage of a suspect class. Suspect classes are those identified by race, alienage or national origin, and fundamental rights are those explicitly or implicitly derived from the Constitution itself.


Doctors filed their action under 42 U.S.C.S. § 1983 to challenge the constitutionality of two New York statutes that criminalized physicians acceding to requests of terminally-ill, mentally competent patients for drugs to hasten death. The district court awarded summary judgment for the state officials.


Is it constitutional to criminalize physicians for acceding to the requests of terminally-ill, mentally competent patients for drugs to hasten death?




The court ruled that the statutes violated the Equal Protection Clause of U.S. Const. amend. XIV because the statutes in question fell within the category of social welfare legislation and therefore were subject to rational basis scrutiny upon judicial review. New York law did not treat equally all competent persons who were in the final stages of fatal illness and wished to hasten their deaths. The court also held that the distinctions made by New York law with regard to such persons did not further any legitimate state purpose, and to the extent that the statutes in question prohibited persons in the final stages of terminal illness from having assistance in ending their lives by the use of self-administered prescribed drugs, the statutes lacked any rational basis and were violative of the Equal Protection Clause. It further noted that physicians who were willing to do so could prescribe drugs to be self-administered by mentally competent patients who sought to end their lives during the final stages of a terminal illness.

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