Student #1
U.S. Government W5
Section 1: Overview
In January 1983, twenty-five year old Nancy Beth Cruzan’s car crashed into a ditch, and
she suffered severe brain damage that left her in a “permanent vegetative state”, unable to move
or speak (Great American Court Cases) . After five years of observing Cruzan in a vegetative
state, Cruzan’s parents and many of her friends became convinced that her life-supporting
treatment should be discontinued. With this opinion in mind, Cruzan’s parents petitioned a local
probate court judge to order her doctors to stop providing life-supporting treatments to their
daughter. To bolster their petition, they had Cruzan’s college roommate testify that prior to the
accident, Cruzan had stated that she would not want to live in any sort of vegetative state
(Gaudin 1308-1309). In response to the petition, the judge ordered Cruzan’s doctors to
discontinue life support. Unfortunately for the Cruzans, their victory at the local court level was
not the end of the battle. Their case ultimately made it to the United States Supreme Court, and it
became known as Cruzan v. Director, Missouri Department of Health. By deciding to hear the
Cruzan’s case, the Supreme Court showed that it was willing to enter into the debate of medical
ethics. Though Cruzan’s state was tragic and unfortunate, the Supreme Court correctly ruled that
Missouri’s law to protect the sacredness of life and its clear and convincing evidence standard
were both constitutional (“The Right to Die and Assisted Suicide”).
Section 2: Facts of the Case
Cruzan’s car accident left her brain without oxygen for fourteen minutes, causing
traumatic brain injury that left her unable to speak or move, and she obtained food and water by
a tube in her stomach. Her vegetative state meant that while Cruzan was conscious, she was
unaware of her surroundings. Despite her state, Cruzan’s life expectancy was considered to be
another thirty years. By 1988, however, Cruzan’s parents, Lester and Joyce Cruzan, requested
that their daughter’s feeding tube be removed and her life-support treatment stopped, stating that
their daughter had previously made statements that she would want her life ended if she were
ever in such a state. Although a local court approved their request based on the premise that their
reasoning met the criteria of the state’s “clear and convincing” evidence requirements, William
L. Webster, Missouri’s attorney general, filed an appeal with the State Supreme Court, citing that
there was not sufficient evidence to prove Nancy Beth Cruzan had ever made such statements.
The Missouri State Supreme Court overruled the decision of the lower probate court, forcing the
Cruzan’s to appeal to the U.S. Supreme Court, making the case of Cruzan v. Director, Missouri
Department of Health the first High Court case to cover the right-to-die conflict (Great American
Court Cases).
Section 3: Legal Issues and Problems Presented by Case
The legal issue of Cruzan’s case concerned who possessed the constitutional right to stop
life-sustaining treatment (Ball 1037). Cruzan’s parents and roommate argued their case, stating
that their knowledge of Cruzan’s wishes prior to the accident was enough evidence to prove that
the patient, when in a previously competent state, would have chosen to not continue lifeextending treatment. While the U.S. Supreme Court respected the constitutional right for a
competent person to refuse treatment, the substituted judgment of Cruzan’s family and friend did
not provide enough evidentiary support that upheld Missouri’s laws concerning clear and
convincing evidence (“The Right to Die and Assisted Suicide”). While the legal issues of the
case did not directly assault or violate a specific amendment, they did violate Missouri’s right to
maintain and uphold laws within its state, one of which stated that Missouri possessed the right
to protect life and safeguard against possible abuses, as well as set definite evidence standards
concerning those issues (Gaudin 1320). The social issues of the case were incredibly
controversial, given the state of the petitioner and the tragic circumstances surrounding the facts
of the case. According to Justice Sandra Day O’Connor, who was one of the presiding justices
when Cruzan reached the Supreme Court, the United States was only beginning to delve into the
debate concerning medical ethics at the time of the case (“The Right to Die and Assisted
Suicide”). The case introduced the concept of a person’s right to control his or her death, which
then stirred debates concerning abortion and euthanasia, causing the U.S. public to assert their
position on the true value of life. The case motivated people to create written wills and take
caution when leaving advance instructions, in case they ever found themselves in a state like
Cruzan’s, since people now recognized that the courts would uphold them, so long as the wills
met the clear and convincing evidence requirements (“The Right to Die and Assisted Suicide”).
Section 4: Discussion of Arguments For and Against
On June 25, 1990, the United States Supreme Court issued its opinion of Cruzan v.
Director, Missouri Dept. of Health. By a 5-4 vote, the court ruled in favor of Missouri (Great
American Court Cases). The bulk of the majority’s opinion, which was written by former Chief
Justice William Rehnquist, focused on two key issues. The first issue was whether the Due
Process Clause of the Constitution allows competent individuals the right to refuse medical
treatment. The court ruled that the Due Process Clause did allow that right. The second issue
focused on whether it was acceptable for Missouri to require the Cruzans to provide “clear and
convincing” evidence that their daughter would want her life-saving treatment ended. The court
ruled that Missouri’s evidentiary requirement was acceptable (“Cruzan v. Director, Missouri
Department of Health”).
In addition to the majority opinion, which was supported by Justices Rehnquist, White,
O’Connor, Kennedy, and Scalia, there were concurring and dissenting opinions. Justice
O’Connor’s concurring opinion expressed why she believed that the Due Process Clause of the
Constitution allows individuals to refuse medical treatment, even in situations when treatment is
necessary to sustain life (“Cruzan v. Director, Missouri Department of Health”).
The Justices in the minority produced two dissenting opinions. One of the dissenting
opinions was the minority opinion. This opinion, written by Justice Brennan and supported by
Justices Marshall and Blackmun, argued that although the Due Process Clause does afford the
right to refuse medical treatment, Missouri’s “clear and convincing” evidence standard was
extreme and unconstitutional (Gaudin 1323). The other dissenting opinion was written by Justice
Stevens. In his opinion, Justice Stevens compared the interest of the state vs. the interest of
Nancy Cruzan. By analyzing both interests and evaluating their arguments, Stevens said that the
state should be more concerned about upholding and protecting the interests of Nancy Cruzan
than trying to encourage the sanctity of life through public policy (“Cruzan v. Director, Missouri
Department of Health”).
Section 5: Agree or Disagree, and Defense of Thesis Statement
In the case of Cruzan v. Director, Dept. of Health, the Supreme Court reached a
conclusive ruling, stating that although the Cruzans claimed to possess evidence that their
daughter would want to be removed from life support, their assertions did not uphold the
requirements needed to meet Missouri’s guidelines concerning substituted judgment. The court
could not make exception to the Cruzans’ unfortunate lack of evidence, and therefore, could not
allow Nancy Beth Cruzan to be removed from life support. Disregarding the clear and
convincing evidence standard for Cruzan would imply that the court took special interest in the
case of Cruzan. When viewed from an emotional perspective, it is easy to understand the
Cruzans’ appeals, which were focused on protecting their daughter’s wishes at all costs. The
legal perspective of the case, however, focuses solely on Missouri’s law, which was created to
preserve the right to life for its people. I agree with the Supreme Court’s decision and disagree
most with Justice Stevens’ dissenting opinion, due to his argument that the state should be more
concerned with Cruzan’s specific case than the application of the protection of life in all cases
through law. While the state of Missouri should protect the interests of Nancy Cruzan, their
responsibility is to do so in a manner that can be applied to every citizen for the sake of the
state’s well-being as a whole. The state cannot take special interest in the rights of one citizen if
those rights cannot be afforded to all other residents of Missouri. By Stevens suggesting that the
state should care more about Nancy Cruzan’s welfare than public policy improvements that
could be reached through the proceedings of the case, he created an argument that contradicted
the purpose of the state government: to uphold laws that protect all residents. The concurring
resolutions of the Supreme Court justices favor the right for Missouri to enforce laws that protect
the rights of all state citizens, including its “clear and convincing” evidence standard. In a
modern world deemed as a culture of death, the Supreme Court’s verdict of the case of Cruzan v.
Director, Dept. of Health supports the states’ right to form laws and protect their people. It also
favors the belief that all life is sacred, and that all citizens should enjoy a Constitutional right to
life that cannot be denied due to substituted judgment or misinterpretation of evidence.