In the 1985 case Bowen, Secretary of Health and Human Services v. American Hospital Association et al., the United States Supreme Court ruled on whether or not hospitals could withhold life-sustaining treatment from infants born with severe physical and mental abnormalities without parental consent. The court held that a regulation issued by the Department of Health and Human Services (HHS), which required federally funded hospitals to provide such treatment unless there were certain exceptions, did not exceed HHS's statutory authority under Title VI of the Civil Rights Act of 1964 or Section 504 Rehabilitation Act of 1973. Furthermore, it was determined that this regulation did not violate either due process rights nor infringe upon parents' constitutionally protected liberty interests in their child’s care, custody, and control. This decision upheld federal regulations requiring medical professionals to administer potentially lifesaving treatments for newborns despite any disabilities they may have.

In the dissenting opinion for Bowen, Secretary of Health and Human Services v. American Hospital Association et al., Justice Stevens argued that the majority's decision to uphold a regulation denying Medicare benefits for services deemed "not reasonable and necessary" was an overreach of administrative power. He contended that Congress did not intend to give such broad discretion to the Secretary in determining what constitutes as "reasonable and necessary." Furthermore, he criticized the majority's interpretation of legislative history, asserting it was flawed because they relied on statements made by individual members rather than collective Congressional intent. He also expressed concern about potential negative impacts on patients who might be denied coverage based on cost-effectiveness rather than medical necessity. Overall, Justice Stevens believed this ruling gave too much authority to administrators at the expense of patient care.