Washington Law Review




In two separate instances adult Jehovah's Witnesses were admitted to hospitals with severe internal bleeding. Doctors in each instance determined that blood transfusions were required to save the patient's life. Each patient refused to consent to transfusions because of his religious beliefs. In one case the patient, who had no minor children, was pronounced incompetent, a conservator to consent to transfusion was appointed by the court, and the transfusion was administered. On appeal, the Illinois Supreme Court reversed. Held: An adult who has no minor children cannot be compelled to take lifesaving blood transfusions against his religious objection. In re Brooks' Estate, 32 Ill. 2d 361, 205 N.E.2d 435 (1965). The other case involved a father of minor children who was a patient in a veterans' hospital. On the hospital's application for an order to authorize the transfusion,

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