Cruzan v. Director, Missouri Department of Health

Case Date: 05/06/1990

1. The United States Constitution does not forbid Missouri to require that evidence of an incompetent's wishes as to the withdrawal of life-sustaining treatment be proved by clear and convincing evidence. Pp. 269-285. [497 U.S. 261, 262] 2. The State Supreme Court did not commit constitutional error in concluding that the evidence adduced at trial did not amount to clear and convincing proof of Cruzan's desire to have hydration and nutrition withdrawn. The trial court had not adopted a clear and convincing evidence standard, and Cruzan's observations that she did not want to live life as a "vegetable" did not deal in terms with withdrawal of medical treatment or of hydration and nutrition. 3. The Due Process Clause does not require a State to accept the "substituted judgment" of close family members in the absence of substantial proof that their views reflect the patient's. This Court's decision upholding a State's favored treatment of traditional family relationships, Michael H. v. Gerald D., 491 U.S. 110 , may not be turned into a constitutional requirement that a State must recognize the primacy of these relationships in a situation like this. Nor may a decision upholding a State's right to permit family decisionmaking, Parham v. J.R., 442 U.S. 584 , be turned into a constitutional requirement that the State recognize such decisionmaking. Court membership Chief Justice William Rehnquist Associate Justices William J. Brennan, Jr. · Byron White Thurgood Marshall · Harry Blackmun John P. Stevens · Sandra Day O'Connor Antonin Scalia · Anthony Kennedy Case opinions Majority Rehnquist, joined by White, O'Connor, Scalia, Kennedy Concurrence O'Connor Concurrence Scalia Dissent Brennan, joined by Marshall, Blackmun Dissent Stevens Laws applied U.S. Const. amend. XIV U.S. Const. amend. IX Cruzan v. Director, Missouri Department of Health, 497 U.S. 261 (1990),[1] was a United States Supreme Court case argued on December 6, 1989 and decided on June 25, 1990. In a 5-4 decision, the Court affirmed the ruling of the Supreme Court of Missouri below and ruled in favor of the State of Missouri, finding it was acceptable to require "clear and convincing evidence" for removal of life support.