Cruzan v. Missouri Department of Health U.S. Supreme Court 1990 Cruzan v. Missouri Department of Health Illustration This case shows how courts interpret the application of the U.S. Constitution to matters that are heard by State Courts. Cruzan v. Missouri Department of Health Facts Nancy Cruzan had an automobile accident and is in the hospital in a “persistent vegetative state.” Her parents ask the hospital to “terminate artificial nutrition and hydration procedures.” The hospital responds that they cannot do it without a court order. Cruzan v. Missouri Department of Health Prior Proceedings Nancy’s parents seek a court order in a Missouri court. That court determines: a) permanent brain damage, b) a fundamental right under state and federal constitutions to refuse or direct the withdrawal of “death prolonging procedures.” and c) Nancy had expressed wishes not to be maintained . . . Cruzan v. Missouri Department of Health In a persistent vegetative state to a roommate prior to the accident. Missouri court grants permission to remove support. The Missouri Dept. of Health appeals to the Supreme Court of Missouri and they reverse the lower court. The Cruzans appeal to the U.S. Supreme Court and they grant certiorari. Diagramming the Case History U.S. Supreme Court Cruzan M.D.H. Missouri Supreme Court M.D.H. Cruzan Missouri Probate Court Cruzan M.D.H. Cruzan v. Missouri Department of Health Issue Does Missouri’s requirement of “clear and convincing evidence” of an incompetent’s wishes violate the U.S. Constitution? Holding NO Cruzan v. Missouri Department of Health Rationale Medical procedures require consent. USSC decided In Re: Quinlan that the “right to privacy” forbids unwanted treatments. Personal rights must be balanced with legitimate state interests. Incompetent person cannot make “right to liberty” choices. The “clear and convincing” rule . . Cruzan v. Missouri Department of Health Is the state’s attempt to prevent abuse. States need not consider “quality of life issues.” A wrong choice to terminate cannot be undone. Missouri S.C. did not find “clear & convincing” (a new standard) evidence. The decision of the Missouri trial court is reversed.
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