Cruzan v. Director, Missouri Department of Health, 497 U.S. 261 (1990), is a landmark decision of the Supreme Court of the United States involving a young adult incompetent. The first "right to die" case ever heard by the Court, Cruzan was argued on December 6, 1989, and decided on June 25, 1990. In a 5–4 decision, the Court affirmed the earlier ruling of the Supreme Court of Missouri and ruled in favor of the State of Missouri, finding it was acceptable to require "clear and convincing evidence" of a patient's wishes for removal of life support. A significant outcome of the case was the creation of advance health directives.
Background
On January 11, 1983, then-25-year-old Nancy Cruzan (born July 20, 1957) lost control of her car while driving at nighttime near Carthage, Missouri. She was thrown from the vehicle and landed face-down in a water-filled ditch. Paramedics found her with no vital signs but resuscitated her. After three weeks in a coma, she was diagnosed as being in a persistent vegetative state (PVS). The hospital refused to do so without a court order, since removal of the tube would cause Cruzan's death. The trial court ruled that constitutionally there is a "fundamental natural right ... to refuse or direct the withholding or withdrawal of artificial life-prolonging procedures when the person has no more cognitive brain function ... and there is no hope of further recovery." The court ruled that Cruzan had effectively 'directed' the withdrawal of life support by telling a friend earlier that year that if she were sick or injured, "she would not wish to continue her life unless she could live at least halfway normally." The Cruzans appealed, and in 1989 the Supreme Court of the United States agreed to hear the case.
The Cruzans' lawyer summarized the constitutional basis for his appeal thus:
Decision
Cruzan was the first "right to die" case the Supreme Court had ever heard, and it proved divisive for the Court.<sup>p. 27</sup> In a 5–4 decision, the Court found in favor of the Missouri Department of Health and ruled that nothing in the Constitution prevents the state of Missouri from requiring "clear and convincing evidence" before terminating life-supporting treatment, upholding the ruling of the Missouri Supreme Court. Reflecting the controversiality of the "end of life" issue, five Justices wrote separate opinions about the case.
Right to die vs. suicide
In court cases, like the Karen Ann Quinlan case and the Elizabeth Bouvia cases, the courts had highlighted the differences between dying from refusing treatment, and dying from suicide. However, in his concurring opinion in Cruzan, Justice Scalia noted that this distinction could be "merely verbal" if death is sought "by starvation instead of a drug."
Justice Scalia argued that refusing medical treatment, if doing so would cause a patient's death, was equivalent to the right to commit suicide. The right to commit suicide, he added, was not a due process right protected in the Constitution. As legal scholar Susan Stefan writes: "[Justice Scalia] argued that states had the right to 'prevent, by force if necessary,' people from committing suicide, including refusing treatment when that refusal would cause the patient to die."
At Cruzan's funeral, her father told reporters, "I would prefer to have my daughter back and let someone else be this trailblazer."
Significance
The Cruzan case set several important precedents: