Quinlan, her father requested to remove the ventilator when she was in persistent vegetative state. She is the first case in the Westlaw database to mention the phrase “persistent vegetative state”. Although some points of law in this case have been subsequently modified in later cases, the Quinlan case is of great historical importance and is still cited by courts.

Joseph Charles Fox had been a Brother in the Membership of the Society of Mary, a religious congregation in the Roman Catholic Church, since 1912, when Fox was 16 years of age. At age 83 in 1979, Brother Fox lapsed into a persistent vegetative state following a routine surgical operation for a hernia. Father Philip K. Eichner, a priest of the Roman Catholic Church, and Director of the Society of Mary at Chaminade, filed a petition in court on 22 Oct 1979 to become a “committee of the person” and then to discontinue life support from Brother Fox. The district Attorney opposed discontinuation of life support. Brother Fox died before the Court of Appeals released their decision, they authorized Father Eichner to terminate the respirator. The court concluded that "the common-law right of bodily self-determination permits a competent adult to refuse life sustaining medical treatment" where, as here, that right outweighed the State's interest in having the treatment continue.

Bertha Colyer was a 69-year-old woman who had sustained a cardiac arrest. She suffered massive brain damage. She was placed on a mechanical ventilator and remained in a comatose, unresponsive state. The Washington court said that “her prognosis for any sort of meaningful existence was zero”. Colyer’s husband, who was her legal guardian, asked the court for permission to remove the ventilator. Although the patient had never explicitly stated her preferences regarding such an act, her husband inferred that this would have been her decision, had she been able to decide. The court reached the same conclusion as Quinlan’s case. Colyer...