John F. Kennedy Memorial Hospital v. Bludworth

Francis Landy was admitted to John F. Kennedy Memorial Hospital (hospital) (plaintiff), and, within two days, Francis suffered permanent brain damage, became irreversibly comatose, and was placed on a mechanical respirator. Francis’s doctors determined he could not be weaned off the respirator and that his condition was terminal. Francis was declared judicially incompetent, and his wife, Gladys Landy, was appointed as his guardian. Gladys submitted Francis’s signed and properly executed living will to Francis’s doctors. Francis’s living will stated Francis did not want to be kept alive by artificial means, including by use of a respirator. Gladys asked the hospital to disconnect Francis from the respirator. The hospital petitioned for a declaratory judgment regarding its potential civil and criminal liability related to the continuation or termination of Francis’s artificial life-support. Although Francis died shortly thereafter, the trial court held the issue remained justiciable because it was applicable to all terminally ill, incompetent patients at the hospital. The trial court held that to terminate life support for a terminally ill, incompetent patient, the court must (1) appoint a guardian for the patient and (2) approve the termination order. The hospital appealed. On appeal, the district court held that terminally ill, incompetent patients had the right to refuse treatment pursuant to the constitutional right to privacy but that court approval was required. The district court then raised a certified question to the Florida Supreme Court about whether the guardian of a terminally ill, incompetent patient needed court approval to terminate life support even if the patient had a living will supporting that decision.