Schiavo and its (in)significance.

Karen Ann Quinlan and Theresa Marie Schiavo are names tied to legal controversies over the withdrawal of medical treatment at the end of life. In re Quinlan1 arose at a time when the rules for decisionmaking for incompetent patients were still unformed and inchoate. It set the framework of analysis for most of the subsequent development in the field. Schiavo,2 on the other hand, arose over a dispute about the application of those rules. In the end, the case of Terri Schiavo will have contributed little to end-of-life law, but it will be remembered because of the bitter battle that erupted between her husband and her parents over whether her feeding tube should be removed and the extraordinary efforts of Florida and then national politicians to overturn a judicial ruling in a pending case. The Schiavo controversy began as a routine case of stopping treatment on a patient in a permanent coma and then metastasized into the Bleak House3 of medical-legal jurisprudence.4 Although there are many stories to tell about the case, I will focus on only two.5 One is the state of the law concerning proxy deci-