In the Matter of Edith M.M. Hayes (1980)
- 4 days ago
- 2 min read
By: Leah O’Donohue
Overview
In the Matter of Edith M.M. Hayes (1980) was an appeal heard in the Supreme Court of Washington regarding court jurisdiction and authority in matters where someone cannot consent to medical procedures due to a mental disability. The lower superior court had originally dismissed the case, claiming it did not have the authority to issue an order of sterilization for someone with a mental disability[1].
Summary
Edith Hayes was born in 1963 with a severe mental disability, and in 1980, her mother had petitioned not only to be assigned as Edith’s guardian but also to have Edith sterilized[1].
The primary issue considered by the court in this case was whether a court had the power to grant a petition for sterilization filed on behalf of someone with a mental disability.
One reason the superior court had originally dismissed the case was a lack of legislation or statutes that granted courts the power to hear such cases. However, on appeal, the Washington Supreme Court determined that no specific legislation was required for the courts to claim jurisdiction, as long as no legislation specifically prevented them from hearing such cases. The Supreme Court also determined that jurisdiction to hear such a petition fell within the state’s constitution, which granted the courts “power to hear and determine all matters legal and equitable in all proceedings known to the common law,” of which this matter fell under[1].
This case was reversed and remanded to the lower court for review. However, the Supreme Court warned that such petitions should be granted only in rare circumstances, after careful consideration, and only when doing so would be in the “best interest” of the disabled person[1].
Impact
This case established that, under applicable legislation, superior courts do have jurisdiction to entertain and act upon a petition for the sterilization of a person with a mental disability. Furthermore, this case established a precedent of careful review when considering petitions filed by guardians of disabled persons when such petitions severely impact bodily autonomy.
Court Documents
In the Matter of the Guardianship of Edith M.M. Hayes, 93 Wn.2d 228, 608 P.2d 635 (1980).
