Cruzan v. Missouri Department of Health
The State of Missouri did not have a legitimate interest in denying the withdrawal of treatment request of Ms. Cruzan’s parents. The trial court provided a decision giving authority to Ms. Cruzan’s parents to withdraw life support. The State Supreme Court of Missouri reversed the decision. On appeal, the State Supreme Court decision was upheld. The decision to not allow the withdrawal of life support was upheld because the parents did not have the authority to make the request on behalf of their daughter, claiming that they did not provide clear and convincing evidence that the daughter wanted the life-sustaining treatment withdrawn.
Although the state did have an interest in the life of Ms. Cruzan, its interest did not outweigh the liberty interest of Ms. Cruzan. The state has only a general interest in the protection and preservation of human life. The state has a right to protect an incompetent person from the possibility of abuse by guardians who may act against his or her wishes. In this case, the parents were the guardian wishing to make the decision for Ms. Cruzan. The parents presented a substantial and sufficient amount of evidence indicating that Ms. Cruzan would have wanted to be taken on life sustaining treatment, and the parents were acting as legitimate guardians with not intent to abuse Ms. Cruzan. The parents provided evidence that Ms. Cruzan would choose to withdraw treatment. Ms. Cruzan had no chance of ever getting her mental facilities returned. Ms. Cruzan had indicated to a friend in the past that she would not choose to be on life support. And, Ms. Cruzan’s parents were adequate representatives of Ms. Cruzan as surrogates.
