Quality of life and end-of-life decisionmaking.

Since 1976, when the New Jersey Supreme Court decided the Karen Ann Quinlan case (In re Quinlan, 355 A.2d 647 (NJ), 1976 cert. denied, 429 US 922, 1976), it has been apparent that the concept of quality of life is fundamental to end-of-life decisionmaking. Yet there has been a great deal of reluctance by courts--which have been the primary engine of lawmaking in end-of-life matters--to use this concept overtly.