AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

A 51-year-old man with moderate mental retardation suffered a stroke and was hospitalized. He was kept alive through a naso-gastric feeding tube. His mother, acting as his limited guardian, directed the termination of this feeding after consulting with family, clergy, and medical personnel. Protection and Advocacy System, Inc. (P & A), a non-profit organization, sought to prevent the termination of the feeding, arguing on behalf of the patient (paras 1-2).

Procedural History

• District Court, May 5, 1999: Ordered the reinstatement of nutrition and hydration, appointed a guardian ad litem, and set a hearing for the following day (para 3).
• District Court, May 7, 1999: Dissolved the prior order requiring nutrition and hydration, effective May 14, 1999, and upheld the mother’s role as the surrogate decision-maker (para 3).

Parties' Submissions

• Plaintiff-Appellant (P & A): Argued that the termination of nutrition and hydration violated the rights of the patient, a developmentally disabled individual, and sought to enjoin the decision (paras 2, 4).
• Defendants-Appellees (Mother and Family): Asserted that the mother, as the patient’s limited guardian and surrogate under the Uniform Health-Care Decisions Act (UH-CDA), had the authority to make health-care decisions, including the withdrawal of life-sustaining treatment (paras 1, 3, 4).
• Amicus Curiae (Professor Robert Schwartz): Provided insights on the UH-CDA, emphasizing its focus on procedural decision-making rather than substantive outcomes (para 16).

Legal Issues

• Did P & A have standing to bring the action under the Uniform Health-Care Decisions Act?
• Was the mother authorized to act as the surrogate decision-maker under the UH-CDA?

Disposition

• P & A lacked standing to bring the action under the UH-CDA (para 26).
• The appeal was dismissed as moot due to the patient’s death (para 27).

Reasons

Per Hartz J. (Alarid and Bustamante JJ. concurring):

• The court analyzed the UH-CDA, which governs health-care decisions, including the withdrawal of life-sustaining treatment. The Act prioritizes procedural mechanisms for identifying decision-makers rather than dictating substantive outcomes (paras 6-16).
• The mother was deemed the appropriate surrogate under the UH-CDA, as she was the patient’s limited guardian and closest available family member (paras 1, 22).
• P & A lacked standing under the UH-CDA because it did not fall within the categories of individuals or entities authorized to petition the court for relief (paras 19-21).
• Federal statutes authorizing P & A to advocate for individuals with disabilities did not override the state-law limitations on standing (paras 23-25).
• The court dismissed the appeal as moot following the patient’s death, noting that the feeding had resumed prior to his passing (para 27).