In re J.M.

J.M. (defendant), a 42-year-old woman, was admitted to The Valley Hospital (plaintiff) with end-stage renal failure. J.M.’s treating physician told J.M. that she would die unless she immediately underwent dialysis. In dialysis, a machine takes over for failed kidneys and passes a patient’s blood through a filter to clean toxins and waste from the blood before returning the cleaned blood to the body. J.M. expressed a clear will to live by consenting to other life-saving treatments and declining to sign a do-not-resuscitate order, but J.M. refused dialysis. Valley Hospital filed an emergency petition to appoint a special medical guardian for J.M., arguing that J.M. was critically ill and lacked capacity to consent to, or refuse, dialysis. J.M. opposed, arguing that she would not die without dialysis because Jesus would cure her. An emergency hearing was held on the hospital’s petition. At the hearing, J.M.’s treating physician, Dr. Mikhail Kotlov, testified that dialysis was necessary to save J.M.’s life and that there was no alternative treatment. Two psychiatrists interviewed J.M. and found that J.M. did not understand that refusing dialysis would be fatal because she was operating under the delusion that Jesus would cure her kidneys and save her life. J.M. did not have either an advance healthcare directive or a healthcare proxy, and her son was a minor.