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In the Matter of Karen Quinlan, an Alleged Incompetent
New Jersey Superior Court, Chancery Division
348 A.2d 801, 137 N.J. Super. 227 (1975)
In 1975, 21-year-old Karen Quinlan was rushed to the hospital unconscious and unable to breathe on her own. The cause of Karen’s condition was unknown, and blood and urine tests showed normal or therapeutic levels of drugs in her system. Despite medical care, Karen remained in a comatose condition known as a persistent vegetative state and dependent on a ventilator. Karen’s physician, Dr. Robert Morse, knew of no treatment that could reverse Karen’s condition but could not say that her condition was irreversible. Karen was not technically brain dead, and some unknown level of recovery was possible. At first, Karen’s distraught parents wanted Dr. Morse to spare no effort in keeping their daughter alive in hopes she might recover. Karen’s parents were active in her care, receiving daily reports on her condition. As time progressed, the reports of her condition were disheartening. Eventually, Karen’s parents and siblings came to the agonizing conclusion that it was best to remove artificial means of life support, such as the respirator, and to allow nature to take its course. Karen’s family recalled how Karen had stated, on three occasions, that she would not want to kept alive by artificial methods. After consultation with his priest, Karen’s father, Joseph Quinlan (plaintiff), signed a release authorizing the removal of life support. Karen’s family thought their wishes would be followed. However, Dr. Morse did not agree with removal of the respirator. When removal was suddenly brought up, Dr. Morse indicated he wanted time to review the matter. Upon review, Dr. Morse’s research showed termination of breathing support to be a significant deviation from standard medical practice. Joseph then petitioned a court to appoint him as guardian of his daughter’s person and property. Joseph petitioned the court to authorize the discontinuance of all life support for Karen, to prevent the doctors and the county prosecutor from intervening, and to prevent prosecution for homicide once Karen was removed from the respirator. The court appointed a guardian ad litem for Karen. The state of New Jersey (defendant) intervened through its attorney general.
Rule of Law
Holding and Reasoning (Muir, J.)
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