Bouvia v. Superior Court
California Court of Appeal, Second District
179 Cal. App 3d 1127 (1986)
Elizabeth Bouvia (plaintiff), a 28-year-old quadriplegic with severe cerebral palsy, was bedridden, in constant pain, able to move only slightly, and dependent on public assistance for care. She had repeatedly expressed a wish to die, including by starving herself. While hospitalized, physicians determined her severe weight loss was life-threatening and inserted a nasogastric feeding tube against her expressed wishes. Bouvia petitioned to have the tube removed. At trial, the county hospital and its staff (defendants) argued the state's interest in preserving life outweighed her wish to refuse treatment, that she was not terminally ill, and that removing the tube would amount to hospital-assisted suicide. The trial court sided with the hospital, emphasizing that Bouvia could live another 15 to 20 years with continued feeding and scrutinizing her motives for wanting the tube removed.
Whether an intelligent, competent individual with an extremely low quality of life may refuse life-saving medical treatment.