Cruzan v. Director, Missouri Department of Health
Cruzan v. Director, Missouri Department of Health, 497 U.S. 261 (1990), was a United States Supreme Court case. It had to do with the right to die. Nancy Cruzan was a woman who was in a persistent vegetative state. Her family wanted to stop life support treatments so she could die. Hospital workers refused to do this without a court order. Eventually, the case made it to the Supreme Court. On June 25, 1990, the Court decided it was legal to require "clear and convincing evidence" that stopping life support is what a person would have wanted.
| 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. |
| Citations | 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 |
| Holding | |
| States may require "clear and convincing evidence that stopping life support is what a person would have wanted, if they cannot make that decision on their own. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Rehnquist, joined by White, O'Connor, Scalia, Kennedy |
| Concurrence | O'Connor |
| Concurrence | Scalia |
| Dissent | Brennan, joined by Marshall, Blackmun |
| Dissent | Stevens |
| Laws applied | |
| Ninth and Fourteenth Amendments | |
Background
On January 11, 1983, Nancy Cruzan's car ran off the road. She landed 35 feet away, face-down in a ditch filled with water. When paramedics arrived, her heart had stopped and she was not breathing.[1] The paramedics resuscitated her, but her brain was damaged by not having enough oxygen. The brain damage caused a persistent vegetative state.[1]
Doctors put a feeding tube into her stomach so food and water could be given through the tube.[1] Without the feeding tube, Cruzan would die from starvation or dehydration, because she could not swallow anything.
In 1988, Cruzan's parents asked her doctors to stop feeding her through the feeding tube.[2] They believed Nancy would not have wanted to live in a persistent vegetative state.[2] She had recently told a friend that if she got badly injured or sick, she would not want to live unless she could live "at least halfway normally."[3] Nancy's parents wanted her to be able to die. However, the hospital refused to take out the feeding tube without a court order.[2]
Lower court decisions
The Cruzans asked a trial court to order the hospital to remove Nancy's feeding tube. The trial court agreed.[4]
The court said that a person has a "fundamental natural right" in the Constitution to have someone make the decision to remove life support "when the person has no more cognitive brain function ... and there is no hope of further recovery."[5] The court said Nancy's conversation with her friend showed that she would not want to live in a persistent vegetative state.[4]
The state of Missouri appealed this decision. The case went to the Supreme Court of Missouri, which reversed the trial court's decision. The Supreme Court of Missouri ruled that no one can refuse treatment for another person, unless:[2]
- The person had a living will, a legal document saying what a person would want in certain medical situations (for example, saying: 'I do not want treatment if I am ever in a persistent vegetative state'); OR
- There was "clear and convincing ... reliable evidence" that the person would have wanted to refuse treatment. That evidence did not exist in the Cruzan case, the Court said.
Supreme Court
The United States Supreme Court agreed to hear an appeal of the Missouri Supreme Court's decision. This was the first "right to die" case that the United States Supreme Court had ever heard.[6]p.27
The Cruzan case divided the Supreme Court. Five of the Supreme Court Justices (judges) wrote their own opinions about the case.[6]p.28 Four disagreed with the decision the Court made. However, the Court ruled, in a 5-4 vote, that the Supreme Court of Missouri made the right decision. They ruled that Missouri did not violate the Constitution when it required 'clear and convincing evidence' that Nancy would have wanted her life support to be ended.[7]
The U.S. Supreme Court did rule that competent people (people who are able to make decisions for themselves) have the right to refuse medical treatment.[7] They said the Constitution gives competent people this right in the Due Process Clause of the Fourteenth Amendment to the United States Constitution.[7]
However, it said things are different for people who are incompetent (people who cannot not make decisions for themselves – for example, because they are in a persistent vegetative state). If another person wants to refuse treatment for someone who is incompetent, they have to show "clear and convincing proof" that refusing treatment is what the person would want.[7]
After the Supreme Court
The Cruzans
After the Supreme Court's decision, the Cruzans went back to the first trial court with new evidence. The court ruled that the Cruzans now had clear and convincing evidence that Nancy would have wanted her life support ended if she was in a persistent vegetative state.[2] On December 14, 1990, Nancy's feeding tube was taken out.[2]
Protesters filed seven different petitions with the court to try to get Nancy's feeding tube put back in, but the court refused.[6]p.29 Then, on December 18, nineteen people went into Nancy's hospital room and tried to reattach her feeding tube themselves; they were arrested.[6]p.29
Nancy Cruzan died on December 26, 1990.[8] She had been in a persistent vegetative state for eight years.
At Nancy's funeral, her father told reporters: "I would prefer to have my daughter back and let someone else be this trailblazer."[6]p.29 Six years later, he killed himself.[9]
Effects
The Cruzan case is one of the most important "right to die" cases in United States history. It set precedents that courts would follow in many cases in the future.[6]
The case also made many Americans interested in writing living wills and other advance directives (documents that tell doctors and family members what they want in certain medical situations, if they cannot make decisions for themselves).[8]
References
- ↑ 1.0 1.1 1.2 Cruzan v. Harmon, 760 S.W.2d 408, 430-433 (Mo. 1988) (en banc) (Higgins, J., dissenting).
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 Gaudin, Anne Marie (July 1991). "Cruzan v. Director, Missouri Department of Health: To Die or Not to Die: That is the Question – But Who Decides?". Louisiana Law Review. 51 (6): 1308–1345. Retrieved March 21, 2016.
- ↑ Cruzan v. Harmon, 760 S.W.2d 408, 433 (Mo. 1988) (en banc) (Higgins, J., dissenting) (quoting the lower trial court)
- ↑ 4.0 4.1 Estate of Cruzan, Estate No. CV384-9P (P. Div. Cir. Ct., Jasper County, Mo., July 27, 1988).
- ↑ Cruzan v. Harmon, 760 S.W.2d 408, 434 (Mo. 1988) (en banc) (Higgins, J., dissenting) (quoting the lower trial court)
- ↑ 6.0 6.1 6.2 6.3 6.4 6.5 Stefan, Susan (March 2016). Rational Suicide, Irrational Laws. Oxford University Press. ISBN 978-0199981199.
- ↑ 7.0 7.1 7.2 7.3 Cruzan v. Director, Missouri Dept. of Health, 110 S. Ct. 2841 (1990).
- ↑ 8.0 8.1 Lewin, Tamar (December 27, 1990). Nancy Cruzan Dies, Outlived by a Debate Over the Right to Die. New York, New York. https://www.nytimes.com/1990/12/27/us/nancy-cruzan-dies-outlived-by-a-debate-over-the-right-to-die.html. Retrieved March 21, 2016.
- ↑ Pace, Eric (August 19, 1996). Lester Cruzan Is Dead at 62; Fought to Let His Daughter Die. New York, New York. https://www.nytimes.com/1996/08/19/us/lester-cruzan-is-dead-at-62-fought-to-let-his-daughter-die.html. Retrieved March 21, 2016.
Other websites
- Quick facts about the Cruzan case in Simple English (from IIT Chicago-Kent College of Law)
- Living Wills and Advance Directives for Medical Decisions (from the Mayo Clinic)