Cruzan v. Director, Missouri Department of Health
|Cruzan v. Director, Missouri Department of Health|
|Argued December 6, 1989|
Decided June 25, 1990
|Full case name||Nancy Beth Cruzan, by her parents and co-guardians, Cruzan et ux. v. Director, Missouri Department of Health, et al.|
497 U.S. 261 (more)|
110 S. Ct. 2841; 111 L. Ed. 2d 224; 1990 U.S. LEXIS 3301; 58 U.S.L.W. 4916
|Prior history||Certiorari to the Supreme Court of Missouri|
1. The United States Constitution does not forbid Missouri to require that evidence of an incompetent's wishes as to the withdrawal of life-sustaining treatment be proved by clear and convincing evidence. Pp. 269-285. [497 U.S. 261, 262]
2. The State Supreme Court did not commit constitutional error in concluding that the evidence adduced at trial did not amount to clear and convincing proof of Cruzan's desire to have hydration and nutrition withdrawn. The trial court had not adopted a clear and convincing evidence standard, and Cruzan's observations that she did not want to live life as a "vegetable" did not deal in terms with withdrawal of medical treatment or of hydration and nutrition.3. The Due Process Clause does not require a State to accept the "substituted judgment" of close family members in the absence of substantial proof that their views reflect the patient's. This Court's decision upholding a State's favored treatment of traditional family relationships, Michael H. v. Gerald D., 491 U.S. 110 , may not be turned into a constitutional requirement that a State must recognize the primacy of these relationships in a situation like this. Nor may a decision upholding a State's right to permit family decision making, Parham v. J.R., 442 U.S. 584 , be turned into a constitutional requirement that the State recognize such decisionmaking.
</td></tr><tr><th colspan="2" style="text-align:center;background-color: #99c0ff; white-space:nowrap">Case opinions</th></tr><tr><th scope="row" style="text-align:left">Majority</th><td>
Rehnquist, joined by White, O'Connor, Scalia, Kennedy</td></tr><tr><th scope="row" style="text-align:left">Concurrence</th><td> O'Connor</td></tr><tr><th scope="row" style="text-align:left">Concurrence</th><td> Scalia</td></tr><tr><th scope="row" style="text-align:left">Dissent</th><td> Brennan, joined by Marshall, Blackmun</td></tr><tr><th scope="row" style="text-align:left">Dissent</th><td> Stevens</td></tr><tr><th colspan="2" style="text-align:center;background-color: #99c0ff; white-space:nowrap">Laws applied</th></tr><tr><td colspan="2" style="text-align:center"> U.S. Const. amend. XIV U.S. Const. amend. IX</td></tr></table> Cruzan v. Director, Missouri Department of Health, 497 U.S. 261 (1990), was a United States Supreme Court case argued on December 6, 1989 and decided on June 25, 1990. In a 5-4 decision, the Court affirmed the ruling of the Supreme Court of Missouri below and ruled in favor of the State of Missouri, finding it was acceptable to require "clear and convincing evidence" of a patient's wishes for removal of life support. A significant outcome of the case was the creation of advance health directives.
On January 11, 1983, Nancy Cruzan lost control of her car. She was thrown from the vehicle and landed face-down in a water-filled ditch. Paramedics found her with no vital signs, but they resuscitated her. After three weeks in a coma, she was diagnosed as being in a persistent vegetative state (PVS). Surgeons inserted a feeding tube for her long-term care.
The issue of this case was whether the State of Missouri had the right to require "clear and convincing evidence" in order for the Cruzans to remove their child from life support.
In a 5-4 court decision, the Court found in favor of the Missouri Dept. of Health. However, it upheld the legal standard that competent persons are able to exercise the right to refuse medical treatment under the Due Process Clause and its implied right to privacy. Because there was no "clear and convincing evidence" of what Nancy Cruzan wanted, the Court upheld the state's policy.
Following the decision
After the case was decided the family went back and found more proof that Nancy Cruzan would have wanted her life support terminated and eventually won a court order to have her removed from life support. Cruzan died 11 days later on December 26, 1990. This decision has influenced many other cases.