The particular circumstances were different, but the issue was germane. As a matter of fact, Browning is profusely cited in the Schiavo decisions.
Was the statute banning the removal of feeding tubes constitutional? No, said Browning.
The law that states medical treatment removal must be directed by the patient is certainly not unconstitutional any way you slice it.
That's what happened in both Browning and Schiavo. Neither of them lost their right to refuse medical treatment just because they could not verbalize their wishes. Previous oral or written expressions are sufficient.
Read Browning dicta if you have any doubts.
Furthermore, being PVS was not a requirement to have the right to refuse feeding tubes. Mrs. Browning was not PVS, she just could not verbalize.
Again, you are likely missing the point I'm trying to make. I know all about Browning. She had a written, advanced directive. Terri did not.
Additionally, Terri was not terminally ill. It was only after the 1999 statute changes that a non-terminally ill person could have a feeding tube removed without a written, advanced directive and that was only in cases of PVS.
Further to that, under Florida's evidence code, Michael Schiavo's testimony of Terri's alleged oral declaration was NEVER admissible. Yet, that was what the court found as clear and convincing evidence of her death wish.
Browning served to set the case law that a person could refuse unwanted intervention, but it did NOT serve to set the case that someone else could refuse intervention for the patient. That has never been set - well.... until now that is.