Gonzales v. Oregon
546 U.S. 243 (2006)

  • Oregon passed the Death With Dignity Act, which allowed doctors to prescribe lethal drugs to terminally ill patients.
  • In order to stop the Act, the US Attorney General (Ashcroft, later Gonzales) issued an interpretive rule saying that physician-assisted suicide violated the Federal Controlled Substances Act (CSA), and would result in revocation of the doctor’s license.
    • The Attorney General felt that he could overrule State law on this issue.
  • Oregon sued for an injunction to block the interpretive rule.
  • The Trial Court found for Oregon. The Department of Justice (DOJ) appealed.
    • The Trial Court found that DOJ did not have the authority under the CSA to regulate physician-assisted suicide.
      • Basically, the CSA had to do with illegal drugs, not with medial decisions. The plain language of the Stature didn’t allow the Attorney General’s action.
      • Medical decisions were a matter the courts had traditionally left up to the States. (aka Federalism).
    • DOJ unsuccessfully argued that the courts are to give judicial deference to Agency decisions, and therefore the Court had no authority to overturn their ruling.
  • The Appellate Court affirmed. DOJ appealed.
  • The US Supreme Court affirmed.
    • The US Supreme Court found that Congress’ intent was clear and that the purpose of the CSA was to regulate criminal activity and illegal drugs.
    • Under the standard established by Chevron U.S.A. Inc. v. Natural Resources Defense Council (467 U.S. 837 (1984)), when Congress’ intent is clear, there is no room for Agency interpretation of the Statute.
    • Therefore, based on the Chevron Doctrine, the courts do not have to give judicial deference to DOJ’s decision.
    • The Court noted that he Federal government does theoretically have the power to limit access to drugs for medical purposes, but the CSA itself did not grant the authority for DOJ to ban suicide drugs.
  • In a dissent it was argued that suicide drugs are not a “legitimate medical purpose” and therefore are excluded from the traditional deference to the States on medical matters.
    • In addition, the Court had just recently said that the CSA did allow DOJ to ban the use of marijuana for medical purposes (See Gonzales v. Raich (545 U.S. 1 (2005)), so how could that be considered consistent with this ruling?