Matter of Sloane v. M.G.

Summary

The Appellate Division, First Department upheld an order authorizing the withdrawal of life-sustaining treatment from M.G., an intellectually and developmentally disabled person in a permanent vegetative state, pursuant to SCPA 1750-b. The court rejected an equal protection challenge arguing that M.G. should have received the same inquiry into prior end-of-life wishes available to a previously competent, nondisabled person under Public Health Law article 29-CC. It held that the differing statutory treatment was rationally related to legitimate state interests and consistent with Matter of Chantel Nicole R.

Holdings

1. Applying SCPA 1750-b to M.G. did not violate equal protection because intellectually and developmentally disabled persons are not similarly situated to previously competent, non-disabled persons for purposes of end-of-life decision-making, and the different statutory treatment is rationally related to legitimate state interests.
2. Although SCPA 1750-b makes the patient's best interests paramount, the best-interests analysis must be patient-centered and must consider the patient's wishes, including moral and religious beliefs, when those wishes are reasonably known or ascertainable with reasonable diligence.
3. The statutory requirements for withdrawal of life-sustaining treatment were satisfied because M.G. was permanently unconscious, had an irreversible medical condition requiring life-sustaining treatment, and continued treatment imposed an extraordinary burden with no meaningful prospect of recovery.

Questions Presented

1. Whether applying SCPA 1750-b's best-interests standard to an intellectually and developmentally disabled person who had previously possessed some health care decision-making capacity, rather than Public Health Law article 29-CC's substituted-judgment framework, violated the Equal Protection Clauses of the Federal and New York Constitutions.
2. Whether SCPA 1750-b requires consideration of the patient's known or reasonably ascertainable wishes, values, moral beliefs, and religious beliefs as part of the best-interests analysis.
3. Whether the evidence established the statutory conditions authorizing withdrawal of life-sustaining treatment, including permanent unconsciousness, irreversible medical condition, and extraordinary burden.

Disposition

affirmed