[agrace]

Question - was the prior statute ruled unconstitutional based on a patient's right to refuse medical treatment? If not that, then what?

[george wythe]

Question - was the prior statute ruled unconstitutional based on a patient's right to refuse medical treatment?

Yes.

Some patient may decide to refuse vital medical treatment because of his religious beliefs, such as Christian Scientists or Jehovah's Witnesses. Another patient may reject vital medical treatment because his current qualify of life is unacceptable.

It does not matter the reason to reject medical treatment. It's a inalienable right to individuals that no state statute can override.