Cruzan v. Director, Missouri Department of Health

Cruzan v. Director, Missouri Department of Health
Cruzan v. Director, Missouri Department of Health
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued December 6, 1989
Decided June 25, 1990
Full case name Nancy Beth Cruzan, by her parents and co-guardians, Cruzan et ux. v. Director, Missouri Department of Health, et al.
Citations 497 U.S. 261 (more)
110 S. Ct. 2841; 111 L. Ed. 2d 224; 1990 U.S. LEXIS 3301; 58 U.S.L.W. 4916
Prior history Certiorari to the Supreme Court of Missouri

1. The United States Constitution does not forbid Missouri to require that evidence of an incompetent's wishes as to the withdrawal of life-sustaining treatment be proved by clear and convincing evidence. Pp. 269-285. [497 U.S. 261, 262]

2. The State Supreme Court did not commit constitutional error in concluding that the evidence adduced at trial did not amount to clear and convincing proof of Cruzan's desire to have hydration and nutrition withdrawn. The trial court had not adopted a clear and convincing evidence standard, and Cruzan's observations that she did not want to live life as a "vegetable" did not deal in terms with withdrawal of medical treatment or of hydration and nutrition.

3. The Due Process Clause does not require a State to accept the "substituted judgment" of close family members in the absence of substantial proof that their views reflect the patient's. This Court's decision upholding a State's favored treatment of traditional family relationships, Michael H. v. Gerald D., 491 U.S. 110 , may not be turned into a constitutional requirement that a State must recognize the primacy of these relationships in a situation like this. Nor may a decision upholding a State's right to permit family decisionmaking, Parham v. J.R., 442 U.S. 584 , be turned into a constitutional requirement that the State recognize such decisionmaking.
Court membership
Case opinions
Majority Rehnquist, joined by White, O'Connor, Scalia, Kennedy
Concurrence O'Connor
Concurrence Scalia
Dissent Brennan, joined by Marshall, Blackmun
Dissent Stevens
Laws applied
U.S. Const. amend. XIV U.S. Const. amend. IX

Cruzan v. Director, Missouri Department of Health, 497 U.S. 261 (1990),[1] was a United States Supreme Court case argued on December 6, 1989 and decided on June 25, 1990. In a 5-4 decision, the Court affirmed the ruling of the Supreme Court of Missouri below and ruled in favor of the State of Missouri, finding it was acceptable to require "clear and convincing evidence" for removal of life support.



On January 11, 1983, Nancy Cruzan lost control of her old car that had no seat belts, was thrown from it and landed face down in a water-filled ditch. Paramedics found her with no vital signs, but they resuscitated her. After a couple weeks of remaining dormant within a coma, she was diagnosed as being in a persistent vegetative state (PVS). Surgeons inserted a feeding tube for her long-term care. Her husband and parents waited for a more substantial recovery, but eventually, after four years, accepted that there was no hope. The accident occurred seven years before they went to the Supreme Court.

Issues presented

The issue of this case was whether the State of Missouri had the right to require "clear and convincing evidence" in order for the Cruzans to remove their daughter from life support.


In a 5-4 decision, the Court found in favor of the Missouri Dept. of Health. However, it upheld the legal standard that competent persons are able to exercise the right to refuse medical treatment under the Due Process Clause. Because there was no "clear and convincing evidence" of what Nancy Cruzan wanted, the Court upheld the state's policy.

Following the decision

After the case was decided the family went back and found more proof that Nancy Cruzan would have wanted her life support terminated and eventually won a court order to have her removed from life support. Cruzan died 11 days later on December 26, 1990.

See also


External links

  • ^ Text of Cruzan v. Director, Missouri Department of Health, 497 U.S. 261 (1990) is available from: Justia · Findlaw

Wikimedia Foundation. 2010.

Look at other dictionaries:

  • Supreme Court of Missouri — Missouri Supreme Court State Seal of Missouri Established 1841 Jurisdiction Missouri …   Wikipedia

  • Nancy Cruzan — Nancy Beth Cruzan (July 20, 1957–December 26, 1990) was a figure in the right to die movement. After an automobile accident left her in a persistent vegetative state, her family petitioned in courts for three years, as far as the U.S. Supreme… …   Wikipedia

  • Human rights in the United States — In 1776, Thomas Jefferson proposed a philosophy of human rights inherent to all people in the Declaration of Independence, asserting that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that… …   Wikipedia

  • Mature minor doctrine — Family law Entering into marriag …   Wikipedia

  • Charles Blakey Blackmar — Charles B. Blackmar Chief Justice of the Supreme Court of Missouri In office July 1, 1989 – June 30, 1991 Preceded by William Howard Billings Succeeded by Edward D. Robertson, Jr …   Wikipedia

  • Euthanasia — For mercy killings performed on animals, see Animal euthanasia. Part of a series on …   Wikipedia

  • Legal burden of proof — This article is about the burden of proof in law. For other uses, see Burden of proof (disambiguation). The burden of proof (Latin: onus probandi) is the obligation to shift the accepted conclusion away from an oppositional opinion to one s own… …   Wikipedia

  • Washington v. Glucksberg — Supreme Court of the United States Argued January 8, 1997 Decided June 26, 1 …   Wikipedia

  • David Orentlicher — Member of the Indiana House of Representatives from the 86th district In office 2002 2008 Succeeded by Edward DeLaney Personal details Political party Democrat …   Wikipedia

  • List of court cases involving the American Civil Liberties Union — This is a list of cases that have involved the American Civil Liberties Union (ACLU) to some degree.1920s1925 * Tennessee v. Scopes (Scopes Trial) paid for John Scopes defense * Gitlow v. New York represented Benjamin Gitlow1927 * Whitney v.… …   Wikipedia

Share the article and excerpts

Direct link
Do a right-click on the link above
and select “Copy Link”

We are using cookies for the best presentation of our site. Continuing to use this site, you agree with this.