Cruzan Ex Rel. Cruzan v. Director, Missouri Department of Health
Headline: Court upholds Missouri rule requiring clear and convincing proof before doctors may stop artificial feeding, allowing states to demand heightened proof while recognizing a liberty interest to refuse life‑sustaining treatment.
Holding:
- Allows states to require clear and convincing proof before life‑support withdrawal.
- Makes families more likely to use living wills or appoint health care proxies.
- Hospitals may refuse removal of feeding without court‑approved evidence.
Summary
Background
Nancy Beth Cruzan was left in a persistent vegetative state after a car crash and was fed by a surgically implanted gastrostomy tube. Her parents, acting as co‑guardians, asked the hospital to remove the artificial nutrition and hydration. A Missouri trial judge authorized removal, but the Missouri Supreme Court reversed, holding that the State could require clear and convincing evidence, such as a living will, that Nancy had earlier expressed a wish to refuse such treatment.
Reasoning
The U.S. Supreme Court assumed for this case that competent people have a liberty interest in refusing medical treatment, including artificially delivered food and water, but focused on whether Missouri’s procedure was constitutional. The Court held the State may require clear and convincing evidence before permitting withdrawal of life‑sustaining nutrition and hydration from an incompetent patient. The majority explained that heightened proof helps protect the State’s interest in preserving life, guards against abuse, and allocates the risk of error where death is irreversible.
Real world impact
The decision leaves intact a constitutional foothold for refusing treatment but makes it easier for States to set stronger procedural safeguards before life‑ending measures are allowed. The Court did not decide whether States must always follow decisions by appointed surrogates; Justice O’Connor’s concurrence said such rules might be constitutionally required in some future case. Concurring and dissenting opinions disagree sharply about how readily States may override family or guardian judgments about withdrawing life support.
Opinions in this case:
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