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Cruzan v. Director, Missouri Dept. of Health

United States Supreme Court
497 U.S. 261 (1989)


Facts

In January 1983, Nancy Cruzan lost control of her car which overturned and Cruzan was later found lying face down in a ditch without any detectable heartbeat or respiratory function. Cruzan subsequently was revived and eventually lived in a state hospital in a persistent vegetative state—a condition in which a person exhibits motor reflexes but evinces no indications of significant cognitive function. The State of Missouri paid for the cost of her care. Nancy’s parents (petitioners) asked hospital employees to terminate her artificial nutrition and hydration, effectively causing her death, after it became apparent that Nancy would never regain her mental faculties. The hospital refused without a court order which the parents obtained thereafter. The trial court found that Nancy had a fundamental right under the state and federal constitutions to refuse or direct the withdrawal of “death prolonging procedures.”  The court also found that when Nancy was 25-years-old she had expressed to a roommate that she would not want life prolonging measures taken unless she could live at least halfway normally. The Missouri Supreme Court reversed, finding that Nancy’s statements to her roommate were “unreliable for the purpose of determining her intent,” and thus “insufficient to support” her parents’ request. The U.S. Supreme Court granted certiorari to review to determine whether Cruzan has a right under the U.S. Constitution which would require the hospital to withdrawal life-sustaining treatment from her.

Rule of Law

Issue

Holding and Reasoning (Rehnquist, C.J.)

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