A few weeks ago, I wrote about a new case filed by a Colorado prisoner who was resuscitated against his wishes. The plaintiff in a similar case, also pending in the U.S. District Court for the District of Colorado, has survived the defendants' motions to dismiss. Helen Granato told paramedics that she did not want intravenous fluids. But Denver paramedics proceeded to insert the IV needle anyway. The court, citing Cruzan, held that Ms. Granato's complaint states a valid claim under 42 U.S.C. 1983 alleging that the paramedics violated her 14th Amendment rights to self-determination.
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