This Note will first analyze and evaluate two competing decision-making models established in other jurisdictions. The Note will then apply that analysis to Schuoler and critically evaluate that decision. The Note will conclude that while the Washington court follows the more appropriate judicial substituted judgment model, its poor articulation of that model may defeat the purpose of the decision: to protect a mental patient's right to refuse ECT.
Gregory S. Marshall, Substituted Judgment and the Right to Refuse Shock Treatment in Washington: In re Schuoler, 11 SEATTLE U. L. REV. 167 (1987).