In September 2014, a 17 year old Connecticut teenager identified in court documents only as “Cassandra C” was diagnosed with Hodgkin’s lymphoma, a rare form of cancer, and ordered by the state to undergo chemotherapy treatment for the disease. After failing to attend the first few appointments with the permission of her parents, she was seized by Connecticut’s Department of Children and Families (DCF) and taken into their custody to begin treatment. Her lawsuit and her plea for permission disease reached the Connecticut Supreme Court and were unanimously rejected on January 8th of this year.
At the center of this case are concerns over judicial activism and government overreach. As a mature 17-year-old with guardian permission, Cassandra argued that there was no rational basis for preventing her from seeking alternative treatment methods. According to Fox CT, her lawyer, attorney Michael Taylor, framed the issue around an individual’s or her own body, saying that the decision “really ought to be up to Cassandra. It ought not to be for the state to jump in and say ‘well, regardless of your decision, we think we know better.’”
The court, however, disagreed. In a monumental ruling, the bench both reaffirmed the established Mature Minor Doctrine of state constitutional law and concluded it was inapplicable to the case. The doctrine is a fundamental principle of many other state judicial systems as well, and it gives minors that the court has deemed to be “mature” the ability to make major life decisions on their own. Examples of its use in Connecticut include the right to have an abortion without parental consent before turning 18, the ability to be charged as an adult for a crime committed while still a minor, and the age at which minors can drive.
The Connecticut Supreme Court, in recognizing the importance of this doctrine, asserted that it was relevant to Cassandra’s issue but decided she did not qualify for its provisions. As the ruling stated, the court “agrees with the trial court that… the respondents have failed to meet their burden of proving under any standard that Cassandra was a mature minor and capable of acting independently concerning her life threatening medical condition.” They concluded that, because Cassandra had run away after swearing under oath that she would undergo treatment if allowed to return home, she had displayed a lack of maturity and thus could not be trusted to make rational decisions about her own body and needed to be under the custody of the DCF.
On the surface, the outcome of this case may seem like a significant loss for proponents of individual liberty and the freedom to make decisions regarding one’s own body. However, a careful reading of the ruling displays its narrow relevance and shows that this decision could actually benefit others in Cassandra’s position in the future. In its decision, the court made a clear use of the Mature Minor Doctrine, unambiguously demonstrating that it was the correct legal precedent with which to analyze a case of this particular nature. The reason Cassandra ultimately lost was because she did not qualify for its protections due to some of her earlier actions — not because the Mature Minor Doctrine did not protect minors from the overreach of the government.
This implies that, had the details of the case been different, Cassandra would have qualified as a mature minor and she would have actually been protected from forced chemotherapy. Technically, in keeping their legal ruling very strict and the binding precedent narrow, the court did not make this rationale explicit, but their decision is still monumental due to a lack of precedent. Before January 8th, the Connecticut Supreme Court had never ruled on this issue, and most other states that follow the Mature Minor Doctrine have not had a case like this before the bench. Even the Supreme Court of the United States has never had to make a similar ruling. Thus, the Connecticut judiciary has found itself in a position where its recent decision could be used as significant precedent in courts around the country of equal or even greater power.
As a result, Connecticut’s ruling could have the widespread effect of actually increasing a minor’s right to protecting his or her own body from unwanted medical treatment. Despite the media’s reaction to the decision, the wording of the court opinion easily allows and even encourages future courts to use the Mature Minor Doctrine and jump to this conclusion. Theoretically, a ruling of this nature should enjoy bipartisan support around the country, with liberals favoring the increased individual liberty and conservatives supporting the protection from government overreach. However, the tough questions remain unanswered: since each case is unique, how will different applications of this ruling impact young lives? Will differences in state laws create significant discrepancy in the administration of healthcare around the nation? And are we comfortable with significantly augmenting the involvement and decision-making power of minors in their own lives, even outside of the medical context?