Cruzan V. Director, Missouri Department Of Health
Case name: Nancy Beth Cruzan, by her parents and co-guardians, Cruzan et ux. v. Director, Missouri Department Of Health
Year decided: 1990
Result: 5-4, in favor of Director, Missouri Department of Health
Related constitutional issue/amendment: Due Process, Privacy (Right to Die)
Civil rights or civil liberties: civil liberties
Significance/precedent: The Court ruled that individuals have the right to refuse and/or withdraw medical treatment under the Due Process Clause; however, those who cannot make medical decisions, whether it be incompetent patients or family members who are not authorized to make decisions on behalf of the patient, are not allowed to exercise these rights. Missouri's compelling state interest to protect the "sanctity of life" and the lack of evidence proving that Cruzan wanted treatment to be withdrawn led the Court to find Missouri's actions to be constitutional. The Court supported Missouri's requirements for "clear and convincing" evidence that the patient would choose to withdraw care because there is no guarantee that families will make choices in the best interests of patients and misguided decisions to withdraw life support are irreversible. As a result of this case, living wills became more common.
Quote from majority opinion: "There is no doubt that statutes requiring wills to be in writing...on occasion frustrate the effectuation of the intent of a particular decedent, just as Missouri's requirement of proof in this case may have frustrated the effectuation of the not-fully-expressed desires of Nancy Cruzan. But the Constitution does not require general rules to work faultlessly; no general rule can. In sum, we conclude that a State may apply a clear and convincing evidence standard in proceedings where a guardian seeks to discontinue nutrition and hydration of a person diagnosed to be in a persistent vegetative state."
Summary of the dissent: Nancy Cruzan's family has stated that she had previously expressed her wish to forgo life support treatment and are convinced that she would not want to be sustained in this manner. "Nancy will never interact meaningfully with her environment again," and she suffers major brain deficits. Nancy Cruzan has the right to not be subject to artificial life sustaining treatment.
Six-word summary: State compelling interest over family's wishes.
Year decided: 1990
Result: 5-4, in favor of Director, Missouri Department of Health
Related constitutional issue/amendment: Due Process, Privacy (Right to Die)
Civil rights or civil liberties: civil liberties
Significance/precedent: The Court ruled that individuals have the right to refuse and/or withdraw medical treatment under the Due Process Clause; however, those who cannot make medical decisions, whether it be incompetent patients or family members who are not authorized to make decisions on behalf of the patient, are not allowed to exercise these rights. Missouri's compelling state interest to protect the "sanctity of life" and the lack of evidence proving that Cruzan wanted treatment to be withdrawn led the Court to find Missouri's actions to be constitutional. The Court supported Missouri's requirements for "clear and convincing" evidence that the patient would choose to withdraw care because there is no guarantee that families will make choices in the best interests of patients and misguided decisions to withdraw life support are irreversible. As a result of this case, living wills became more common.
Quote from majority opinion: "There is no doubt that statutes requiring wills to be in writing...on occasion frustrate the effectuation of the intent of a particular decedent, just as Missouri's requirement of proof in this case may have frustrated the effectuation of the not-fully-expressed desires of Nancy Cruzan. But the Constitution does not require general rules to work faultlessly; no general rule can. In sum, we conclude that a State may apply a clear and convincing evidence standard in proceedings where a guardian seeks to discontinue nutrition and hydration of a person diagnosed to be in a persistent vegetative state."
Summary of the dissent: Nancy Cruzan's family has stated that she had previously expressed her wish to forgo life support treatment and are convinced that she would not want to be sustained in this manner. "Nancy will never interact meaningfully with her environment again," and she suffers major brain deficits. Nancy Cruzan has the right to not be subject to artificial life sustaining treatment.
Six-word summary: State compelling interest over family's wishes.