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Cruzan v. Missouri Dept. of Health (1990)
Transcript of Cruzan v. Missouri Dept. of Health (1990)
Right to Die
Nancy Cruzan (25 at the time) was in a critical car accident in 1983 that left her paralyzed, and in a coma for 3 weeks.
After being paralyzed for over 5 years and having everyone realize she was never going to recover, Nancy's parents decided ending her life support would be best.
The hospital would not allow this to happen without the consent of the courts.
Missouri Supreme Courts declared this unconstitutional because Nancy did not make this decision herself, therefore the case was taken to the Supreme Court for a decision.
The plaintiffs, Nancy's parents, felt the decision made by the Missouri Supreme Courts was one that did not consider Nancy's suffering, or the costs of the life support. They felt, as Nancy's parents, that they should've been able to make this life or death situation, because they didn't want Nancy to suffer any longer than she had.
Under the Due Process Clause, because Nancy was incompetent, and she could not make rational decisions herself, she was allotted a surrogate, to make them for her, which became her parents. Although, Nancy's parents wanted the best for her, the courts had to make sure this was in the best interest of the patient.
Is there a family right of sovereignty that overrides the state's claim of preservation of life?
The state has to consider, would Nancy want to continue living in the state she is in? Considering she left no life ending instructions and she can't make the decision to end her own life.
The Missouri Supreme Courts felt if the Cruzan's removed Nancy's feeding tubes and ceased her life support, this would be considered murder under Missouri law.
Missouri believes it is constitutionally right, because the state believed in preservation of life, despite the condition of the patient.
Precedent / Importance
Today, documents called "living wills" eliminate the stress and confusion the Cruzans endured.
Living wills, which are signed in front of witnesses, allows a person to state what they wish to happen to them if they were to become catastrophically injured.
Also, a legal order called “power of attorney” allows a friend or relative to speak on a person's behalf when a traumatic injury occurs.
The Courts decided to deny the Cruzans the right to end Nancy's life.
The Supreme Court felt that the Cruzans did not have adequate evidence that this was what Nancy wanted for herself.
The Courts felt that the Cruzan case was a matter of liberty not privacy.
The vote was 5-4 to uphold Missouri's stand in the case.
Majority: Justice Brennan wrote, "Cruzan's right to liberty outweighed any interests of the state's"
Minority: Justice Stevens, who agreed with Justice Brennan, wrote, "The meaning and completion of her life should be controlled by persons who have her best interests at heart—not by a state legislature concerned only with the 'preservation of human life.”
After further discussion, another case was held on behalf of the Cruzans and ultimately they were granted the right to remove Nancy's feeding tubes, she died shortly after.
Casebriefs LLC. "Cruzan v. Director, Missouri Department of Health | Casebriefs." Casebriefs. Casebriefs LLC, 2014. Web. 17 Feb. 2014.
Pearson Education, Inc. "Cruzan v. Director, Missouri Dept. of Health (1990)." Infoplease. Infoplease, 2005. Web. 16 Feb. 2014.