Cruzan v. Missouri Dept. of Health: What Most People Get Wrong

Cruzan v. Missouri Dept. of Health: What Most People Get Wrong

Imagine being twenty-five years old, driving home on a cold January night in 1983, and suddenly, your world flips—literally. Nancy Cruzan’s car overturned on Elm Road in Jasper County, Missouri. She was found face down in a ditch, not breathing, her heart stopped. Paramedics brought her back, but her brain had been without oxygen for maybe fourteen minutes. That’s a long time. Too long.

Nancy didn't wake up. She ended up in what doctors call a persistent vegetative state (PVS). She could breathe on her own and her heart beat just fine, but the "Nancy" part—the personality, the thoughts, the consciousness—was essentially gone. For years, she was kept alive by a feeding tube.

This is where the legal nightmare of Cruzan v. Missouri Dept. of Health began. It wasn't just a court case; it was a seven-year battle over who gets to decide when a life is no longer "life."

Honestly, it’s kinda heartbreaking when you look at the details. Nancy’s parents, Lester and Joyce Cruzan, eventually realized their daughter wasn't coming back. They asked the hospital to remove the feeding tube. The hospital said no. They needed a court order because, well, removing the tube meant Nancy would die.

A trial court actually agreed with the parents. But then the Missouri Supreme Court stepped in and flipped the script. They ruled that since Nancy couldn't speak for herself, the state had an interest in "preserving life" unless there was "clear and convincing evidence" that she wouldn't want to live like that.

What "Clear and Convincing" Actually Means

In most civil cases, you just need to prove something is more likely than not—basically 51%. But "clear and convincing" is a much higher bar. It’s the legal version of saying, "We need to be really, really sure."

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Missouri’s high standard meant that casual conversations weren't enough. Nancy once told a housemate she wouldn't want to live "like a vegetable." The Missouri Supreme Court basically said, "That’s too vague. We need more."

Why the Supreme Court Got Involved

By 1990, the case reached the U.S. Supreme Court. It was the first "right to die" case they ever took. The big question: Does the Constitution give you a right to refuse medical treatment, even if it keeps you alive?

The decision was a 5-4 split. Very close. Chief Justice William Rehnquist wrote the majority opinion. Basically, the Court said two big things:

  1. Competent people have a right to refuse treatment. If you’re awake and aware, you can say "no" to a ventilator or a feeding tube. That’s part of your "liberty" under the 14th Amendment.
  2. States can set their own high bars for incompetent people. Since Nancy couldn't speak, Missouri was allowed to demand that "clear and convincing" proof. They weren't required to, but they could.

The Court was worried that if they made it too easy to pull the plug, family members might make the wrong choice—either by mistake or for darker reasons, like inheritance money. They chose to "err on the side of life."

The Twist Most People Forget

Most people think the Supreme Court ruling was the end of the story. It wasn't. Because the Court said Missouri could require more evidence, the case went back to a local probate court.

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The Cruzans didn't give up. They found more witnesses. Former colleagues and friends came forward testifying that Nancy had been very clear about her wishes in past conversations. This time, the judge said it was enough. The "clear and convincing" bar was finally met.

On December 14, 1990, the feeding tube was removed. Nancy died twelve days later. It had been nearly eight years since the accident.

Why This Still Matters in 2026

You’ve probably heard of "Living Wills" or "Advance Directives." You can thank Nancy Cruzan for those. Before this case, the legal path for refusing treatment was a total mess.

Shortly after she died, Congress passed the Patient Self-Determination Act. Now, almost every time you’re admitted to a hospital, they ask if you have an advance directive. They have to tell you your rights.

The Real-World Legacy

  • The Power of Attorney: It’s not just for old people. This case proved that every adult needs to name a "healthcare proxy"—someone who knows your wishes and can speak for you.
  • The Definition of "Medical Treatment": The Court clarified that artificial nutrition (feeding tubes) is a medical treatment, not just "basic care" like brushing someone's hair. This means it can be refused.
  • State Differences: Because the Supreme Court didn't set a single national rule, your rights can change depending on which state line you cross. Some states are way more relaxed than Missouri was.

Actionable Steps for Your Own Peace of Mind

Nobody likes thinking about car accidents or persistent vegetative states. But if the Cruzan v. Missouri Dept. of Health case taught us anything, it’s that "casual talk" doesn't hold up in court.

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If you want to make sure your family never has to go through what the Cruzans did, you've gotta do more than just mention it over dinner.

1. Pick your person.
Don't just assume your spouse or parents know what to do. Formally name a healthcare proxy. This is someone you trust to make the hard calls when you can't.

2. Get it in writing.
Fill out an Advance Healthcare Directive. Be specific. Do you want a feeding tube? For how long? If there’s zero chance of recovery, what’s your "stop" point?

3. Use the "Clear and Convincing" standard yourself.
Write down your values. If you feel strongly about not being kept alive by machines, say so in your documents. Use those exact words if you have to.

4. Talk to your doctor.
Make sure your primary care physician has a copy of your directive on file. Hospitals often struggle to find these papers in an emergency.

The Cruzan case was a tragedy that turned into a legal landmark. It forced America to grow up and face the reality of modern medicine: just because we can keep a body functioning doesn't always mean we should. Ensuring your wishes are "clear and convincing" today is the only way to protect your autonomy tomorrow.


Next Steps:

  • Search for your state’s specific Advance Directive forms (they vary by state).
  • Schedule a 15-minute talk with your designated healthcare proxy to explain your specific "line in the sand."
  • Upload a digital copy of your living will to your phone’s "Emergency Info" or "Health" app for quick access.