The Washington Supreme Court in In re Grantsought to determine whether life sustaining treatment could be legally withheld from a terminally ill, non-comatose, incompetent individual. In its December 1987 slip opinion, a majority of the court expanded on its previous decisions empowering third parties, including guardians, families, and physicians, to withhold and withdraw life sustaining treatment from incompetent individuals. This was accomplished by characterizing artificial nutrition and hydration as removable, life sustaining medical treatment. The court also gave third parties the power to remove artificial nutrition and hydration before the incompetent individual in question slips into a coma or persistent vegetative state. After numerous, bizarre procedural twists, however, any semblance of a majority opinion disappeared, and the resulting decision serves only to further complicate an already complex and controversial issue.
Stephen P. VanDerhoef, In re Grant: Where Does Washington Stand on Artificial Nutrition and Hydration?, 13 SEATTLE U. L. REV. 197 (1989).