I'm not a judge and I'm not a lawyer. Judicial activism? Personally, no I don't think so. More probably bad lawyering on the behalf of the Schindler's attorney.
Congress did not demand injunctive relief for Terri, and would have been in Constitutional Purgatory if they had. Three levels of Federal court ruled against the Schindlers, and I don't believe that was a conspiracy. There must have been something lacking in the case they presented.
Ummm....an out of control judiciary acting on its own whims, outside of established law, and brand new law is Constitutional Purgatory .............