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Cruzan v. Director, Missouri Department of Health

United States Supreme Court
497 U.S. 261 (1990)


Facts

Nancy Cruzan (plaintiff) was involved in a serious automobile accident. Paramedics found Cruzan without respiratory or cardiac functions, but revived her at the scene. After emerging from a three-week coma, Cruzan remained in a persistent vegetative state in which she exhibited no cognitive function, but retained motor reflexes. To assist her, surgeons implanted a gastrostomy feeding and hydration tube into Cruzan. The State of Missouri (defendant) bore the cost of her medical care. When it became clear that Cruzan had no chance of recovering, Cruzan’s parents (plaintiff) requested the nutrition and hydration tube be removed, which would cause her death. The hospital refused to do so without a court order. The trial court granted Cruzan’s parents petition to remove the tube. The court concluded that Cruzan had a fundamental right to refuse life-prolonging treatment and that she had expressed to a friend that she would not want to continue her life “unless she could live at least halfway normally.” The Missouri Supreme Court reversed and held that the evidence of Cruzan’s desire not to continue life-prolonging treatment was not clear and convincing and thus Cruzan’s parents lacked the authority to effectuate the court order. The United States Supreme Court granted certiorari.

Rule of Law

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Issue

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Holding and Reasoning (Rehnquist, C.J.)

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Concurrence (O’Connor, J.)

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Concurrence (Scalia, J.)

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Dissent (Brennan, J.)

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Dissent (Stevens, J.)

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