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M09.03.002 Brother Fox (Eichner v. Dillon): Best Interest Standard
In Eichner v. Dillon, the New York Court of Appeals addressed the complexities of making medical decisions on behalf of individuals who have never been competent or for whom there is insufficient knowledge to determine their subjective wishes. This case established significant legal guidance regarding the application of the best interest standard for such patients.
Key Points of the Case
Background of the Case
- Case Name: Eichner v. Dillon
- Court: New York Court of Appeals
- Issue: Determining appropriate standards for decision-making for patients who have never been competent.
Court’s Ruling
The New York Court of Appeals recognized the challenges in determining the actual, subjective wishes of individuals who have always been incompetent. In such situations, using a substituted judgment standard, which attempts to deduce what the patient would have chosen if competent, is often deemed impractical. Therefore, the court outlined an alternative approach—the best interest standard.
The Best Interest Standard
Definition
The best interest standard aims to decide what a reasonable person would conclude after carefully weighing the benefits and burdens of each medical intervention. It considers:
- Medical Benefits: The potential positive outcomes of a particular medical intervention.
- Risks or Burdens: Any potential suffering, adverse effects, or risks associated with the intervention.
- Quality of Life Considerations: How the intervention may impact the patient’s dignity, comfort, and overall well-being.
Application of the Standard
Under the best interest standard:
- Decisions are objective rather than subjective, focusing on what would be in the general benefit of the patient.
- Decision-makers: Any person or group involved in the decision-making process (e.g., healthcare providers, legal guardians, courts) should ideally arrive at the same conclusion since the standard is objective rather than personalized.
Table: Best Interest Standard vs. Substituted Judgment Standard
| Aspect | Best Interest Standard | Substituted Judgment Standard |
|---|---|---|
| Decision Focus | decision-makers Role | Subjective, based on what patient would choose if competent |
| Applicable Situation | The patient has always been incompetent or has unknown preferences | Patient previously competent or preferences partially known |
| Decision-makers Role | Assess benefits and burdens impartially | Emulate patient’s likely choices based on known preferences |
| Outcome Consistency | High consistency among decision-makers | Variable, depending on familiarity with patient’s wishes |
Points to Remember
- The best Interest Standard is preferred when the patient’s wishes are unknown or they have always been incompetent.
- Objective Decision-Making: Aims to arrive at a consensus based on the hypothetical reasoning of a reasonable person.
- Substituted Judgment Standard is suitable only if sufficient knowledge about the patient’s preferences exists.
Bibliography
- Eichner v. Dillon, New York Court of Appeals decision. Legal database: FindLaw.
- Best Interest Standard and Substituted Judgment. Hastings Center Report.