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Schiavo ex rel. Schindler v. Schiavo
United States District Court for the Middle District of Florida
357 F. Supp. 2d 1378 (2005)
Terri Schindler grew up in a close Roman Catholic family in New Jersey. Terri met Michael Schiavo (defendant) and dated him for two years before they wed. Michael and Terri Schiavo moved to Florida, and Terri’s parents (plaintiffs) and sister followed. Terri began treatment with physicians for an undisclosed condition. Terri suffered cardiac arrest apparently due to a systemic potassium imbalance. Michael called 911, the paramedics performed cardiopulmonary resuscitation and took Terri to the hospital, and Terri never regained consciousness. Terri remained in a comatose, vegetative state at a nursing home with nourishment and hydration delivered through a feeding tube. Over eight years after Terri’s cardiac arrest, Michael filed a petition as guardian and surrogate decision maker for the authority to discontinue Terri’s artificial life support as a decision she would choose for herself. The state court granted Michael’s petition according to Florida’s statutory scheme that allowed for substituted judgment of an incapacitated patient. Michael discontinued Terri’s artificial life support and moved her to a hospice facility. Congress passed and the president signed emergency legislation designed to give Terri’s parents an opportunity to challenge the discontinuation of Terri’s life support. Terri’s parents brought an action in the district court, alleging that the state-court proceedings that allowed Michael as the healthcare proxy for an incapacitated person to discontinue Terri’s artificial life support violated Terri’s due-process and equal-protection rights under the Fourteenth Amendment to the United States Constitution. Terri’s parents also claimed that the state-court proceedings violated Terri’s right to the free exercise of her Roman Catholic religion under the First Amendment to the United States Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA). Terri’s parents sought a temporary restraining order directing Michael and the hospice facility to return Terri to the hospital to restart her artificial life support.
Rule of Law
Holding and Reasoning (Whittemore, J.)
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