cruzan v. Missouri
Year: 1990
Result: 5-4, favor Missouri
Related Constitutional issue/Amendment: 9th Amendment, 14th Amendment (due process clause)
Civil rights or Civil liberties: Civil liberties
Significance/precedent: People deemed "incompetent" do not maintain the rights of Due Process from the 14th Amendment to withdraw from medical care. The state's interest in preserving life outweighs the interests of the individual's family, especially when there is not substantial evidence (i.e. a living will) of the individual's wishes. With no guarantee of the family's best interests also being the incompetent person's best interests, and with the dangerous and irreversible nature of withdrawing care, the Supreme Court upheld the state's decision to preserve the life of Cruzan.
Quote from majority opinion: "But there is no automatic assurance that the view of close family members will necessarily be the same as the patient's would have been had she been confronted with the prospect of her situation while competent. All of the reasons previously discussed for allowing Missouri to require clear and convincing evidence of the patient's wishes lead us to conclude that the State may choose to defer only to those wishes, rather than confide the decision to close family members."
Summary of dissent: Nancy Cruzan should be allowed to "die with dignity" because the state does not have a general interest in preserving her life when she is essentially, not even living it. Previous statements from Cruzan are sufficient evidence that she should be granted her right to die instead involuntarily being kept in "suspended animation where death commences while life, in some form, continues.
6-word summary: Individual interests>State interests> family interests
Result: 5-4, favor Missouri
Related Constitutional issue/Amendment: 9th Amendment, 14th Amendment (due process clause)
Civil rights or Civil liberties: Civil liberties
Significance/precedent: People deemed "incompetent" do not maintain the rights of Due Process from the 14th Amendment to withdraw from medical care. The state's interest in preserving life outweighs the interests of the individual's family, especially when there is not substantial evidence (i.e. a living will) of the individual's wishes. With no guarantee of the family's best interests also being the incompetent person's best interests, and with the dangerous and irreversible nature of withdrawing care, the Supreme Court upheld the state's decision to preserve the life of Cruzan.
Quote from majority opinion: "But there is no automatic assurance that the view of close family members will necessarily be the same as the patient's would have been had she been confronted with the prospect of her situation while competent. All of the reasons previously discussed for allowing Missouri to require clear and convincing evidence of the patient's wishes lead us to conclude that the State may choose to defer only to those wishes, rather than confide the decision to close family members."
Summary of dissent: Nancy Cruzan should be allowed to "die with dignity" because the state does not have a general interest in preserving her life when she is essentially, not even living it. Previous statements from Cruzan are sufficient evidence that she should be granted her right to die instead involuntarily being kept in "suspended animation where death commences while life, in some form, continues.
6-word summary: Individual interests>State interests> family interests