In 2019, New Jersey became one of a handful of states to legalize doctor-assisted suicide with the enactment of the Medical Aid in Dying for the Terminally Ill Act (the “Act”). Among the limits of this Act is the requirement that the terminally ill patients seeking to end their lives must reside in the State of New Jersey.
A New Jersey doctor challenged this residency requirement in federal court, arguing that the Act violated federal law by restricting the right to assisted suicide to New Jersey residents. Other plaintiffs challenging the Act had included Delaware and Pennsylvania residents who were terminally ill; they died before the case was decided.
In a December 5, 2025 decision, the Third Circuit Court of Appeals concluded that there were important justifications for the residency requirement, including protecting vulnerable patients and their doctors, and avoiding friction among states. It concluded that the residency requirement was carefully tailored to further those justifications.
The Court’s Opinion noted that only ten states and the District of Columbia allow doctor-assisted suicide, and included an Appendix listing doctor assisted-suicide laws by State. For those states that permit doctor-assisted suicide, all of those laws include important safeguards; the vast majority of those states limit doctor-assisted suicide to residents.
In sum, the Appeals Court affirmed the District Court’s dismissal of the complaint.
A copy of the U.S. Court of Appeals decision in Bryman v. Murphy can be found here.