Until this year, no state or federal appellate court had ever held that there was a right to assisted suicide no matter how narrow the circumstances or stringent the conditions. In 1996, however, within the span of a single month, two federal courts of appeals so held; in an 8-3 majority of the Ninth Circuit (sitting en banc) in Compassion in Dying v. Washington and a three-judge panel of the Second Circuit in Quill v. Vacco. What heartened proponents of a right to physician-assisted suicide even more, and pleased those resistant to the idea even less, was that the two courts which found a constitutional right in assisted-suicide did so by invoking different provisions of the Fourteenth Amendment. The Ninth Circuit relied on the Due Process Clause and the Second Circuit turned to the Equal Protection Clause.
Kamisar, Yale. "The 'Right to Die': On Drawing (and Erasing) Lines." Duq. L. Rev. 35, no. 1 (1996): 481-521. (Symposium on Physician-Assisted Suicide.)