In re Jane Doe

In In re Jane Doe, 262 Ga. 389, 392 (2) (a) (418 SE2d 3) (1992), the Supreme Court of Georgia reiterated that In re L. H. R. addressed only its own specific circumstances. The Court then ruled that the parents and the physicians treating 13-year-old Jane Doe could have decided whether to withdraw life support without seeking judicial approval and further held that "the opinion did not preclude considering the propriety of deescalation under other circumstances." Id. The Court reasoned that while medical technology and society's understanding of death and dying continue to evolve and change, we cannot mandate a single, static formula for deciding when deescalation of medical treatment may be appropriate. Rather, the Court endorsed the view that medical decision-making for incompetent patients is most often best left to the patient's family (or other designated proxy) and the medical community, and the courts remain available to decide controversial cases. Id.