Cruzan v. Director, Missouri Department Of Health

497 U.S. 261 (1990)

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Nature of the Case

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Facts

Cruzan (P) was injured in an automobile accident. The paramedics were able to restore her breathing and heartbeat at the accident site. An attending neurosurgeon diagnosed her as having sustained probable cerebral contusions compounded by significant anoxia. She was reduced to a vegetative state, with no reasonable chance of recovery. P's parents requested that the life support be terminated, causing P's death. The hospital employees refused to do so on the basis of a state law requiring clear and convincing evidence of an individual's prior consent in order to cease life support procedures. P's parents sued the Director of the Missouri Department of Health (D) on P's behalf. They claimed that the law violated P's constitutional 'right to die.' The trial court found that permanent brain damage results after six minutes in an anoxic state. The court estimated that P had been deprived of oxygen for 12-14 minutes. P remained in a coma for three weeks and then progressed into an unconscious state in which she was able to orally ingest some nutrition. Subsequent rehabilitative efforts proved unavailing. The trial court granted relief. The Supreme Court of Missouri reversed by a divided vote. The court recognized a right to refuse treatment embodied in the common law doctrine of informed consent but expressed skepticism about the application of that doctrine in the circumstances of this case. The court also declined to read a broad right of privacy into the State Constitution which would 'support the right of a person to refuse medical treatment in every circumstance,' and expressed doubt as to whether such a right existed under the United States Constitution. It then decided that the Missouri Living Will statute, Mo.Rev.Stat. § 459.010 et seq. (1986), embodied a state policy strongly favoring the preservation of life. The court found that Cruzan's statements to her roommate regarding her desire to live or die under certain conditions were 'unreliable for the purpose of determining her intent, and thus insufficient to support the co-guardians claim to exercise substituted judgment on Nancy's behalf.' It rejected the argument that Cruzan's parents were entitled to order the termination of her medical treatment. The court also expressed its view that 'broad policy questions bearing on life and death are more properly addressed by representative assemblies' than judicial bodies. The Supreme Court granted certiorari.