In re Matter of Dubreuil

Patricia Dubreuil (defendant) was admitted to Memorial Hospital (hospital) (plaintiff) on April 5, 1990. Patricia was pregnant. On admission, Patricia signed a consent form agreeing to receive a blood transfusion if needed. The next day, doctors decided that a Caesarian section was needed to deliver Patricia’s baby. Patricia signed a form consenting to the Caesarean section but this time withheld consent to a blood transfusion because of her religious convictions as a Jehovah’s Witness. Patricia’s baby was delivered by Caesarian section on April 6. Because of a clotting disorder, Patricia lost considerable blood but again refused to consent to a transfusion even though doctors determined it was necessary to save her life. Patricia became unconscious. Patricia’s husband, Luc Dubreuil, was contacted and consented to the blood transfusion. Luc and Patricia were separated, and their four children were living with Patricia. Patricia’s two brothers supported Luc’s decision. None of the men were Jehovah’s Witnesses. Patricia’s mother, who was a Jehovah’s Witness, opposed Luc’s consent. Physicians proceeded with the transfusion on April 6. The physicians believed that Patricia would need more transfusions, and the hospital petitioned a district court for an emergency declaratory judgment allowing the transfusions to proceed despite Patricia’s objections. During the hearing, Patricia regained consciousness and communicated to the hospital’s counsel that she opposed further transfusions. Midafternoon on April 6, the court ruled in favor of the hospital, finding that the interests of the state and society in ensuring that Patricia’s minor children were cared for outweighed Patricia’s wishes. The transfusions continued, and Patricia lived. Patricia sought discretionary review from the Florida Supreme Court.