Facts
Nancy Cruzan was rendered comatose after being involved in a car accident. The accident left her in a “persistent vegetative state” (Guadin, 1990). Surgeons fed her intravenously. After it became apparent that she had no chance of recovery, Nancy’s parents (petitioners) requested their daughter be discontinued from life support. The medical personnel refused to honor this request without court approval (Guadin, 1990). The Cruzans took the case to a Missouri district court, and the Court granted the request. However, the director of Missouri State Department of Health insisted on a high standard proof (Guadin, 1990). Thus, the department took the case on appeal to Missouri Supreme Court. The Court refused to authorize the termination. The Cruzans appealed to the United States Supreme Court.
Issue (s)
Did the Cruzan have the right under the U.S. Constitution to request the Missouri State Health Department to withdraw from life-support treatment?
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Did Missouri’s high standard proof requirement for terminating life support violate the U.S. Constitution?
Holding
No and No. The Missouri Supreme Court held that the Cruzan did not have the right to request the medical facility to withdraw Nancy from life-support treatment. The Court also held that Missouri’s high standard proof requirement for terminating life support did not violate the U.S. Constitution.
Reasoning
Under the Due Process Clause, a competent individual has a constitutionally protected liberty interest in refusing medication (Kanaboshi, 2006). On the contrary, for incompetent individuals, a higher standard of evidence is required. This is because such individuals might not always make voluntary and informed decisions that the incompetent person would have agreed with. The Due Process Clause protects an individual’s interest in life (Kanaboshi, 2006). More to this, it gives an individual the right to refuse lifesaving treatment. Missouri has the right to protect these individual’s rights by imposing heightened evidentiary requirements. More to this is that, even when available, parents and other family members may not always act in the best interest of the patient. It is for this reason that a State is entitled to safeguard against such abuses.
Right of Privacy
The right of privacy refers to the protection of an individual’s information from public scrutiny. This right is not specifically mentioned in the U.S. Constitution (Sharp, 2013). Most often, this right is protected by statutory law. One such statutory law which safeguards individual privacy is the Health Information Portability and Accountability Act (HIPAA). This statutory act protects individuals’ health information (Sharp, 2013). Another statutory law that protects individual privacy is the Federal Trade Commission (FTC), which enforces the right to privacy in a number of privacy policies and privacy statements (Sharp, 2013).
References
Guadin, A. M. (1990). Cruzan v. Director, Missouri Department of Health: To Die or Not to Die: That Is the Question-But Who Decides. La. L. Rev. , 51 , 1307.
Kanaboshi, N. (2006). Competent Persons' Constitutional Right to Refuse Medical Treatment in the U.S. and Japan: Application to Japanese Law. Penn St. Int'l L. Rev. , 25 , 5.
Sharp, T. (2013). Right to privacy: Constitutional rights & privacy laws. [Online]. Retrieved February 29, 2020, from https://www.livescience.com/37398-right-to-privacy.html
