Cruzan v. Director, Missouri Department of Health 1990

AuthorDaniel Brannen, Richard Hanes, Elizabeth Shaw
Pages518-524

Page 518

Petitioner: Nancy Beth Cruzan, by her parents and co-guardians

Respondent: Director, Missouri Department of Health

Petitioner's Claim: That the state of Missouri had no legal authority to interfere with parents' wish to remove a life-sustaining feeding tube from their daughter's comatose body.

Chief Lawyer for Petitioner: William H. Colby

Chief Lawyer for Respondent: Robert L. Presson, Attorney General of Missouri

Justices for the Court: Anthony Kennedy, Sandra Day O'Connor, Chief Justice William H. Rehnquist, Antonin Scalia, Byron R. White

Justices Dissenting: Harry A. Blackmun, William J. Brennan, Jr., Thurgood Marshall, John Paul Stevens

Date of Decision: June 25, 1990

Decision: Ruled in favor of Missouri by determining the state did not violate the Fourteenth Amendment guarantee of liberties of the comatose patient.

Significance: The case marked the first time the U.S. Supreme Court ruled in a right-to-die case. The Court ruled that rejection of life preserving medical treatment by a competent person is a liberty protected by the Constitution.

Page 519

Right-to-die is a general term referring to a patient's right to die by natural causes when refusing life sustaining treatment. The refusal can be made by a competent (able to make decisions on their own) patient realizing that their decision may mean death.

Even before the birth of America, right-to-die had been considered a liberty in English common law (legal based on practices rather than laws). As under the U.S. Constitution, such liberties are fundamental freedoms in which a person may participate relatively free from government interference.

Right-to-die is quite different from assisted suicide which was prominent in news in the 1990s. Assisted suicide is when a doctor helps individuals to take their own lives. The patient dies not by natural causes, but by human action.

The first case involving right-to-die that come to the nation's attention was that of Karen Ann Quinlan in 1975. The case involved a young woman in a permanent vegetative state and her family's legal battle to remove life support from her. The case was decided in the New Jersey Supreme Court with a ruling to honor the family's wishes. Not until 1983 did a right-to-die case reach the U.S. Supreme Court.

An Accident on an Icy Missouri Road

Twenty-five year old Nancy Beth Cruzan, driving on an icy Missouri road in January of 1983, lost control of her car. The accident left Cruzan brain damaged and in what doctors described as a "permanent vegetative state." She could not move, speak, or communicate, and showed no indication of thinking abilities, but was able to breath on her own. About a month after the accident a feeding tube was inserted into her stomach through which she received all her nutrition and fluids (food and water). Doctors estimated with this life support she could be kept alive another thirty years.

Clear and Convincing Evidence

By 1988, Lester and Joyce Cruzan...

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