In re Sampson, 29 N.Y.2d 900 (1972)

The state has the authority to order medical treatment for a child, even over the religious objections of the parent, when such treatment is deemed necessary for the child’s welfare.

Summary

This case addresses the extent of the state’s power to order medical treatment for a minor despite the religious objections of the parent. The New York Court of Appeals affirmed the lower court’s decision to order surgery for a 15-year-old child with a disfiguring condition, notwithstanding the mother’s religious objection to blood transfusions, which were deemed necessary for the surgery’s success. The court emphasized that the state’s power to intervene in neglect proceedings extends beyond life-threatening situations and that religious objections do not automatically bar necessary medical intervention.

Facts

A 15-year-old child had a disfiguring condition that required surgery for correction. The child’s mother, a Jehovah’s Witness, objected to blood transfusions, which doctors deemed necessary for the surgery’s success, based on her religious beliefs. The Family Court directed the surgery, including the possibility of blood transfusions, over the mother’s objections.

Procedural History

The Family Court initially ordered the surgery. The Appellate Division affirmed the Family Court’s decision. The New York Court of Appeals granted leave to appeal and ultimately affirmed the Appellate Division’s order, thereby upholding the state’s authority to order the surgery.

Issue(s)

Whether the state can order medical treatment, including blood transfusions, for a minor over the religious objections of the parent when the treatment is considered necessary for the child’s welfare, even if the condition is not life-threatening.

Holding

Yes, because the state’s power to intervene in neglect proceedings extends to situations where medical treatment is necessary for a child’s welfare, and religious objections do not automatically bar such interventions, especially when the treatment is deemed crucial for the success of the required surgery.

Court’s Reasoning

The court reasoned that its prior holding in Matter of Seiferth did not limit the Family Court’s statutory power to order necessary surgery only to drastic or mortal circumstances. The court emphasized that the present case involved a serious physiological impairment. The court cited Matter of Santos v. Goldstein and other cases to support the proposition that religious objections to blood transfusions do not present an absolute bar, especially where the transfusion is necessary for the success of required surgery. The court referenced Jehovah’s Witnesses in State of Wash. v. King County Hosp., affirming the principle that the state can authorize medical treatment for a child, even when it conflicts with the parent’s religious beliefs. The court recognized the state’s interest in protecting the welfare of children, which can override parental religious objections when medical intervention is deemed necessary for the child’s well-being. The court stated, “What doubt there may have been was laid to rest by the case oí Jehovah’s Witnesses in State of Wash. v. King County Hosp.” This emphasizes the precedence of ensuring a child’s welfare over parental religious objections when medical necessity is established. The court’s decision underscores the balancing act between parental rights, religious freedom, and the state’s parens patriae authority to protect children.