Cruzan v. Director, Missouri Department of Health

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Cruzan v. Director, Missouri Department of Health

Supreme Court of the United States

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.

Citations:	497 U.S. 261; 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

Holding

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adduced at trial did not amount to clear and convincing proof of Cruzan's desire to have hydration and nutrition withdrawn.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 decisionmaking, Parham v. J.R., 442 U.S. 584 , be turned into a constitutional requirement that the State recognize such decisionmaking.

Court membership

Chief Justice: William Rehnquist
Associate Justices: William J. Brennan, Byron White, Thurgood Marshall, Harry Blackmun, John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy

Case opinions

Majority by: Rehnquist
Joined by: White, O'Connor, Scalia, Kennedy
Concurrence by: O'Connor
Concurrence by: Scalia
Dissent by: Brennan
Joined by: Marshall, Blackmun
Dissent by: Stevens

Laws applied

U.S. Const. amend. XIV U.S. Const. amend. IX

Cruzan v. Director, Missouri Department of Health, 497 U.S. 261 (1990),^[1] 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 ruled in favor of the State of Missouri, finding it was acceptable to require "clear and convincing evidence" for removal of life support.

1 Background
2 Issues presented
3 Decision
4 External links

[edit] Background

On the night of January 11, 1983, Nancy Beth Cruzan lost control of her car as she traveled down Elm Road in Jasper County, Missouri. The vehicle overturned, and Cruzan was discovered lying face down in a pile of bushes without detectable respiratory or cardiac function. Paramedics were able to restore her breathing and heartbeat at the accident site, and she was transported to a hospital in an unconscious state. An attending neurosurgeon diagnosed her as having sustained probable cerebral contusions compounded by significant anoxia (lack of oxygen). The Missouri trial court in this case found that permanent brain damage generally results after 6 minutes in an anoxic state; it was estimated that Cruzan was deprived of oxygen from 12 to 14 minutes. She remained in a coma for approximately three weeks and then progressed to an unconscious state in which she was able to orally ingest some nutrition. In order to ease feeding and further the recovery, surgeons implanted a gastrostomy feeding and hydration tube in Cruzan with the consent of her then husband. Subsequent rehabilitative efforts proved unavailing. She lay in a Missouri state hospital in what is commonly referred to as a persistent vegetative state: generally, a condition in which a person exhibits motor reflexes but evinces no indications of significant cognitive function. The State of Missouri bore the cost of her care.

[edit] Issues presented

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 daughter from life support.

[edit] Decision

In a 5-4 decision, the Court found in favor of the Missouri Dept. of Health. However, it upheld the legal standard that incompetent persons are able to exercise the right to refuse medical treatment under the Due Process Clause. Because there was no "clear and convincing evidence" of what Nancy Cruzan wanted, the Court upheld the state's policy.

Note: 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.