Public Health Trust of Dade County v. Wons

Case Summary for my Law & Bioethics graduate school course

by Don Stacy

 

Public Health Trust of Dade County, Appellant, v. Norma Wons, Appellee, Supreme Court of Florida, 541 So.2d 96 (1989).

 

COURT

Supreme Court of Florida

 

PARTIES

Plaintiff/Appellant: Public Health Trust of Dade County

Defendant/Appellee: Norma Wons

 

FACTS

Norma Wons, a devout Jehovah’s Witness and mother of two minor children, was admitted to Jackson Memorial Hospital for management of dysfunctional uterine bleeding. Her physicians recommended a blood transfusion. She was advised that she would probably die unless she proceeded with the blood transfusion. Based on her religion, the patient declined the blood transfusion (she believed the Bible forbade receiving blood from outside her own body). She was deemed to be competent at the time of her decision.

 

PLAINTIFF/APPELLANT’S CONTENTIONS

The Public Heath Trust of Dade County, the operator of Jackson Memorial Hospital, petitioned the Circuit Court to force Norma Wons to receive a blood transfusion, citing the State’s “compelling“ interests in maintaining life (the patient) and protecting innocent third parties (the two minor children).           

 

DEFENDANT/APPELLEE’S CONTENTIONS

Norma Wons cited her constitutional rights of free religious exercise and privacy as legitimate reasons for her refusal to receive the blood transfusion.

 

PROCEDURAL HISTORY

As noted above, the Public Health Trust of Dade County petitioned the Circuit Court to force Norma Wons to receive a blood transfusion, citing the State’s interests in maintaining life (the patient) and protecting innocent third parties (the two minor children). The Circuit Court granted the petition, reasoning that the right of the two minor children to be raised by two loving parents overrode the patient’s rights of free religious exercise and privacy. Her hospital physicians then administered the blood transfusion when she was unconscious.

After regaining consciousness, Norma Wons appealed the Circuit Court’s decision to the Third District Court. The Third District Court reversed the ruling of the Circuit Court. The Third District Court found that the “compelling” interests cited by the State were not sufficient to override the patient’s constitutional rights to privacy and free religious exercise.

The Public Health Trust of Dade County then appealed the decision of the Third District Court to the Supreme Court of Florida.

 

ISSUES

  • Does a competent adult have a lawful right to refuse a blood transfusion, for religious reasons, without which the patient may well die?
  • Have State courts ruled that there are “compelling” State interests that may override a competent adult patient’s right to refuse medical treatment and, if so, what are these “compelling” State interests?
  • Do State courts have the authority to judge the “reasonableness” or validity of religious beliefs?

 

HOLDINGS

  • A competent adult has a lawful right to refuse a blood transfusion, for religious reasons, without which the patient may well die.
  • State courts have ruled that the following criteria are “compelling” State interests that may override a competent adult patient’s right to refuse medical treatment: Preservation of life, protection of innocent third parties, prevention of suicide, and maintenance of the ethical integrity of the medical profession.
  • State courts do not have the authority to judge the “reasonableness” or validity of religious beliefs.

 

RULES

  • A competent adult has a lawful right to refuse a blood transfusion, for religious reasons, without which the patient may well die.
  • A competent adult patient’s right to refuse medical treatment can be overridden in circumstances that trigger “compelling” State interests.
  • State courts do not have the authority to judge the “reasonableness” or validity of religious beliefs.

 

RESULT

The Supreme Court of Florida upheld the ruling of the Third District Court.

 

IMPLICATIONS/ETHICAL CONSIDERATIONS

This case established that a competent adult has a lawful right to refuse a blood transfusion, for religious reasons, without which the patient may well die.