Fosmire v. Nicoleau, 75 N.Y.2d 218 (1990)

A competent adult has the right to refuse medical treatment, including life-saving blood transfusions, even when that person is a parent of a minor child; this right can only be overridden by a compelling state interest, and New York has no law requiring a parent to undergo medical treatment to benefit a child.

Summary

Denise Nicoleau, a Jehovah’s Witness, refused blood transfusions during and after childbirth due to religious beliefs. Despite this, a hospital obtained a court order to administer transfusions, citing the state’s interest in preserving her life and protecting her child. The New York Court of Appeals ultimately held that Nicoleau, as a competent adult, had the right to refuse medical treatment, even if life-saving, and that the state’s interest in preserving her life as a parent was not compelling enough to override her right to bodily autonomy and religious freedom, absent any specific law requiring her to undergo treatment.

Facts

Denise Nicoleau, a practical nurse and Jehovah’s Witness, informed her physician and the hospital before childbirth that she would not consent to blood transfusions due to her religious beliefs. She signed a form specifically excluding blood transfusions. After a Cesarean section, she hemorrhaged severely. Doctors informed her she would die without a transfusion, but she and her husband refused consent based on religious grounds. The hospital then sought and obtained a court order for the transfusions without prior notice to the Nicoleaus.

Procedural History

The Supreme Court of Suffolk County issued an ex parte order authorizing the hospital to administer blood transfusions. The Appellate Division vacated this order, holding that the Supreme Court erred by issuing the order without notice to the patient and her family. The hospital appealed to the New York Court of Appeals.

Issue(s)

1. Whether a competent adult has the right to refuse medical treatment, including blood transfusions, based on religious beliefs, even when that person is a parent of a minor child.
2. Whether the State’s interest in preserving the life of a parent for the benefit of their child is a sufficiently compelling interest to override the parent’s right to refuse medical treatment.
3. Whether the hospital was required to provide notice and a hearing to the patient before seeking a court order authorizing the transfusions.

Holding

1. Yes, because a competent adult has a common-law and statutory right to determine their own medical treatment, which is not absolute but can only be superseded by a compelling state interest.
2. No, because New York has not established a legal precedent or statute that prioritizes the state’s interest in preserving a parent’s life for the sake of their child over the parent’s right to refuse medical treatment based on religious beliefs and bodily autonomy.
3. Yes, because applications for court-ordered medical treatment affect the important rights of patients and should generally comply with due process requirements of notice and the right to be heard before the order is signed.

Court’s Reasoning

The Court recognized a competent adult’s right to determine their medical treatment under common law and statutes (Public Health Law §§ 2504, 2805-d), a right coextensive with the liberty interest protected by the State Constitution’s due process clause. It emphasized that this right is not absolute but can be overridden by a compelling state interest. The Court distinguished this case from situations involving children where the state has a clear interest in protecting minors. While acknowledging the state’s interest in preserving life and protecting children, the Court found no statute or legal precedent in New York requiring a parent to undergo medical treatment for the benefit of a child. The Court rejected the argument that declining essential medical care equates to parental abandonment, stating that such an interpretation would extend the concept of abandonment beyond recognized boundaries and conflict with other substantial interests. The Court also pointed out that notice and an opportunity to be heard should be provided before court-ordered medical treatment is authorized, except in cases of extreme exigency. The Court noted, “To the extent that existing statutory and decisional law manifests the State’s interest on this subject, they consistently support the right of the competent adult to make his own decisions by imposing civil liability on those who perform medical treatment without consent, although the treatment may be beneficial or even necessary to preserve the patient’s life”.