Armstrong Reflects on How Quinlan Case Shaped NJ End-of-Life Choice

June 15, 2025

Judge Paul Armstrong was a newly graduated attorney when he was approached by Joe Quinlan, father of Karen Ann Quinlan, in 1975 to help remove life-sustaining measures. Judge Armstrong, who retired from the bench in 2015, would later become a pioneer of patients’ rights as a member of the New Jersey Superior Court. He remains a board member on the Karen Ann Quinlan Hospice in Newton, NJ, and has served as a Senior Health Administration Fellow and Judge in Residence at the Bloustein School since 2017.

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NorthJersey.com for USA Today, June 4, 2025

Americans cherish their freedoms — the inalienable rights to life, liberty and the pursuit of happiness ingrained in the Declaration of Independence.

But well into the 20th century, one right we now consider fundamental was still unrecognized: the right to die, to determine our own fate when it comes to modern medical interventions that can keep the body alive long after the conscious mind ceases to function.

Today, Americans are free to declare those rights in the form of advance directives such as a living will.

For that, we have one New Jersey family to thank: the parents and siblings of Karen Ann Quinlan, whose faith carried them through the arduous process of turning their tragedy into a legal victory that changed the way Americans approach the end of life. They were aided by a collection of attorneys and judges on both sides of the life-or-death case who chose to work “as adversaries but not enemies.”

Karen, then 21, fell into an irreversible coma after attending a party in Sussex County on April 15, 1975. She died 40 years ago, on June 11, 1985, in a Morris County nursing home.

The legal battle waged between those dates made its way to the New Jersey Supreme Court, with a rabid press corps following the case — and the family — at every step. The court’s decision would affect legal systems across the globe.

“We all had the sense that history had touched us on the shoulder, and asked us to address something that previously had not been addressed,” said Paul Armstrong. The then-young attorney pleaded the case for Karen’s parents to gain guardianship of their adopted daughter, remove her from a hospital respirator and let her “die with dignity.”

The final ruling, handed down on March 31, 1976, by former New Jersey governor and then-state Supreme Court Chief Justice Richard J. Hughes, was announced nationwide by Walter Cronkite, the venerable CBS News anchor. “The Supreme Court of New Jersey ruled today on an issue that has tormented the consciences of the legal and medical professions,” he told viewers of his nightly national broadcast.

Who was Karen Ann Quinlan?

To Joseph and Julia Quinlan, their daughter was a “gift from God.” A devoutly Catholic, middle-class couple from Roxbury, they had endured miscarriages and a stillbirth before adopting Karen in 1954.

A good athlete and aspiring singer, Karen graduated from Morris Catholic High School before moving with a group of friends to nearby Byram. She fell into her coma after a party at a local tavern. Authorities said she was seen ingesting alcohol and tranquilizers that night, but a definitive cause for her condition was never established.

Three months later, with Karen in a vegetative state with no seeming hope of recovery, Joe and Julia made the difficult decision. They asked doctors at Saint Clare’s Hospital in Denville to remove their daughter from the respirator believed to be the only thing keeping her alive.

The doctors and the hospital denied their request, citing religious concerns. In September, Joe Quinlan filed a petition in state Superior Court in Morristown seeking the right to remove the respirator. A local judge refused.

In Trenton, Hughes recognized the import and urgency of the case and agreed the Supreme Court should hear arguments, bypassing appellate courts. The Court’s unanimous,59-page decision granted the Quinlans’ wishes, setting a legal precedent that would eventually be translated into 64 languages.

“The law, equity and justice must not themselves quail and be helpless in the face of modern technological marvels presenting questions hitherto unthought of,” Hughes wrote. “We do not question the State’s undoubted power to punish the taking of human life, but that power does not encompass individuals terminating medical treatment pursuant to their right of privacy.”

Quinlans turned tragedy into a mission

Karen was taken off the respirator and moved to the Morris View nursing home outside Morristown. To the surprise of doctors and her family, she survived for nine years until her death in 1985.

Joe Quinlan, who was awarded the Distinguished Service Cross for bravery during World War II, died in 1991, six years after his daughter.

Four decades later, Julia Quinlan, now 98, still lives independently in Sussex County. She’s not far from the Karen Ann Quinlan Home for Hospice in Fredon, a $5 million, 10-bed facility on a hill overlooking pastoral farmland that the family opened in 2014.

Karen’s younger sister, Mary Ellen, is the board chair of Quinlan Care Concepts, which operates the hospice facility and its home hospice, palliative care and bereavement services. Younger brother John directs the foundation that supports the hospice, also serving as its chief fundraiser.

Living nearby, John and Mary Ellen dote on their mom, seeing to her needs. Julia said she misses her eldest child, although “it’s hard” to recall those difficult days when her family coped with grief, the court system, an invasive media and the public scrutiny that came with their controversial decision.

“It was a very, very difficult time, because we knew that we were losing Karen, and yet there was not a thing that we could do about it,” Julia said. “I cried a lot. I just cried day and night because I knew I would never have Karen again. I’d never hold her again.”

She still cries today, she said.

“She was just a beautiful young woman, so loving and caring,” Julia said. “I wish everyone could have known her.”

Beyond the courtroom, the attention took a toll. Mary Ellen Quinlan recalled “the photographers, the being stared at everywhere you went.”

Fake nuns and faith healers

The spotlight glared brighter and brighter as the case made front-page news. Karen’s high school graduation photo appeared in newspapers and on TV across the country, at times on a nightly basis.

“If I went food shopping with my mother, people would come up and they would tell her these horrible, heartbreaking stories about things that happened to them,” Mary Ellen said. “Everybody’s got a story, and they see you, and that’s what they remember, their story, and they want to share it.”

“It was a very public case,“ John Quinlan added.

“In history, you have to look back to the Lindbergh case to see something so public. And then there was also the paparazzi. They were obsessed with the idea of getting a picture of quote-unquote ‘the coma girl.’ At the nursing home, they caught people trying to get in dressed as a nun, dressed as a priest. They caught a photographer climbing the outside wall to get a picture.”

Even worse, John said, were the “true believers,” frequently evangelical Christians, who arrived insisting they could fix the Quinlans’ misery.

“They came from all over the country and even other countries, because they knew that if they could just lay their hands on Karen, that they could cure her through the power of Jesus,” John said “And many of them didn’t like taking ‘no’ for an answer. So it was actually a little bit frightening.”

The Quinlans leaned on their own beliefs as devout Catholics to cope with the assaults on their privacy.

“I could not have gotten through it without my faith,” Julia said.

The publicity did produce one significant benefit: Proceeds from a book deal and 1977 TV movie helped to support the launch of the Karen Ann Quinlan Memorial Foundation in 1980.

Pioneers in hospice care

Also funded through private donations, the foundation and the Quinlan hospice center have remained nonprofits in an industry that was quickly overtaken by private companies. “We only charge when it’s absolutely necessary,” Julia said.

“The first three years, there was no Medicare reimbursement,” John added. “Then in 1983, Congress finally started reimbursing for hospice care, and we never looked back. But then, of course, once there is money in it, then the for-profits come in.”

The Quinlans have received buyout offers over the years, but John said, “We will remain the last independent, freestanding, nonprofit hospice in the country, if that’s what it takes.”

“If I had to say one thing that I feel is the most important, it’s that Medicare regulations state that a family has the right to choose their own hospice provider,” John said. “And if they ask for a certain hospice by name and they are refused, then that doctor or discharge planner is violating Medicare regulations.”

Hospice care “has become a giant for-profit industry,” he added. “Our little hospice in Newton is up against a $9.5 billion industry.”

Julia still retains the board titles of founder and CEO but has retired from the day-to-day demands of running a hospice.

“I was a young woman. How would I ever have thought about this?” she said. “But I did, and I am so thankful, because we have helped thousands of people. And to me, that’s what life is about. I have a life to be thankful for.”

Young attorneys on a landmark trial

On May 9, three of the attorneys whose involvement in the Quinlan case changed the course of their careers returned to the historic Morristown courtroom where Superior Court Judge Robert Muir presided over a trial that is still studied today. A portrait of Muir hangs on the wall there along with those of past judges who presided over the courtroom, which was constructed in 1827.

A courtroom sketch of the Quinlan proceedings hangs in the Morris County Courthouse gallery along with those of other famous trials held there over the past two centuries.

All three attorneys who argued in the case were impossibly young for the path laid before them. It led to what everyone knew would be a life-or-death decision.

Paul Armstrong was just two years out of Notre Dame Law School and in private practice in Dover when Joe Quinlan, then a shipping manager at pharmaceutical company Warner-Lambert, walked through his door in 1975, seeking the right to put his daughter in God’s hands.

The strategy was to petition Muir to grant the parents guardianship rights to their 21-year-old daughter, since she could no longer express her own wishes. The couple’s desire to remove Karen from the life-sustaining respirator turned what might have been a routine case into a legal “polestar,” Armstrong, now 80, recalled.

“In America, sooner or later, the things we hold most sacred end up in a courtroom,” he said at the May 9 forum, part of a retrospective series on landmark New Jersey Supreme Court cases.

Donald Collester was only 35 when he was named the county’s first full-time prosecutor in 1975.

“I didn’t think I would be dealing with questions like ‘what is death?'” Collester said. “These were questions that had roots in religion, philosophy. I assumed there were other cases that raised some of these questions. My assumptions were incorrect, as I would soon find out.”

‘This may get some press coverage’

Collester joked with Armstrong at the forum, recalling the early days of their work together. They were “adversaries but not enemies,” both agreed.

“I remember saying to you, ‘This may get some local press coverage,'” Collester said. “And of course, when the complaint was filed, it was — boom! literally the next day.”

Tom Curtin completed the trio of Quinlan trial veterans. They gathered as part of a series marking the 75th anniversary of the state Supreme Court.

Another young graduate of Notre Dame Law School, and a devout Catholic himself, Curtin was the second attorney to be appointed as Karen’s legal guardian while her father petitioned the court.

“At the time, there was no clear understanding of what death was,” said Curtin, who is still in private practice in Morristown. “This was a perfect confluence of the judiciary, the bench, the bar and faith-based litigants, where they came together and worked toward a solution that turned out to be the right one.”

All three attorneys credited Muir for his forethought and insight in uncharted waters.

Though he decided against the Quinlans’ guardianship request, Muir’s ruling was designed to build “a factual basis that would be perfect to take up to the New Jersey Supreme Court,” Armstrong said.

Muir wrote that “since Karen Quinlan is medically and legally alive, the Court should not authorize termination of the respirator, that to do so would be homicide and an act of euthanasia.”Still, he continued: “In this age of advanced medical science, the prolongation of life and organ transplants, it is not my intent, nor can it be, to resolve the extensive civil and criminal legal dilemmas engendered.”

“Muir understood the importance of the case,” Armstrong said.

The Quinlan case’s lasting bonds

Later in their careers, Armstrong and Collester served on the bench as well, Armstrong in Somerset and Morris counties and Collester in both Morris County and the Appellate Division. Each is now recognized as a legal scholar.

Muir, who also went on to serve on the appellate court, died in 2022 after a long battle with Alzheimer’s disease.

Armstrong, who remains close with the Quinlans, is a board member of the Quinlan hospice.

“We’re particularly proud of the fact that Judge Muir was cared for by the Quinlan hospice many decades after he presided over the case,” he said.

“Paul has been with us from Day One,” Julia Quinlan added. “He loves us and we love him.” Armstrong, she noted, “has never, ever charged for anything.”

“Everyone participated on a pro bono basis,” Armstrong added. “Some of the best doctors in the world testified in this case and never sent a bill. Cases like this bring out the best in people.”

“I played a small part; we all played a small part,” he continued. “The largest parts were played by the Quinlan family and Richard J. Hughes. The genius, the empathy, the practicality, the understanding he had of the human problem — he essentially found that these kinds of decisions are better made at the bedside than they are in a courtroom.”

The decision and Hughes’ approach to the law remain relevant, Armstrong said. He sees parallels between the U.S. Supreme Court’s legal bombshell in 2022, when it overturned Roe v. Wade and the constitutional right to an abortion, and the Quinlan case 50 years ago.

“Various state supreme courts are now wrestling with fundamental decisions that women can make at the beginning of life,” he said. “We were wrestling with the decisions you can make at the end of life.”

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Armstrong Reflects on How Quinlan Case Shaped NJ End-of-Life Choice

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