Cruzan v. Missouri Dept. of Health
Nancy Cruzan was an “unconscious vegetable” because of an automobile accident. She had severe brain damage and was kept alive with the artificial life support. After many years on life support, there was still no progress in Nancy's being.
Cruzan’s parents petitioned the Missouri Supreme Court to authorize, on their daughter’s behalf to withhold artificial life support. The U.S. Supreme Court decided the state was in a better position to decide.
Cruzan lost control of her car as she traveled down Elm Road in Jasper County, Missouri. The vehicle overturned and Cruzan ended up in a ditch face down.
The car accident happened of January 11, 1983. Argued December 6, 1989. Decided June 25, 1990.
The Missouri Court felt that there was no evidence that Nancy wished to end her artificial life support. The four dissenters argued that Nancy’s constitutional right to reject unwanted medical treatment was being violated.
Cruzan was unconscious at the time her parents requested to cut off her life support.
After suffering from many injuries, Nancy cannot make the decision herself.
In absence of court approval, Cruzan's parents had to be denied their wishes.
Nancy's family and friends claimed that Nancy had expressed wanting to refuse life support if she was ever in a vegetation stage of hospitalization, the court found this unreliable for the purpose of the intent.
There is an absence of formalities and clear evidence of Nancy's wishes.
Plaintiff's Arguments:
Earlier in her life, Nancy expressed that she would not want to live off of life support if she ever was in a situation where she could not live without it.
Her parents waited many years for Nancy to revive from her state of vegetation but she never did.
In the opinion of the plaintiff, the State of Missouri had no right to require “clear and convincing evidence” in order for them to remove their daughter from life support.
The Verdict
In a 5-4 decision the Court affirmed the ruling of the Supreme Court of Missouri...
...in FAVOR of the State of Missouri finding it acceptable to require “clear and convincing evidence” for removal of life support.
This reinforced that competent persons are able to exercise to right to refuse treatment under the Due Process Clause.
Eventually the family went back and retrieved more evidence that Nancy Cruzan wished to withhold her life support, and eventually won a court order to have her removed from life support.
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