cruzan v director, missouri department of health summarycruzan v director, missouri department of health summary

Cruzan v. Director, Missouri Department of Health, Casebriefs is concerned with your security, please complete the following, The Role Of The Supreme Court In The Constitutional Order, Judicial Efforts To Protect The Expansion Of The Market Against Assertions Of Local Power, The Constitution, Baselines, And The Problem Of Private Power, LSAT Logic Games (June 2007 Practice Exam), LSAT Logical Reasoning I (June 2007 Practice Exam), LSAT Logical Reasoning II (June 2007 Practice Exam). This site is protected by reCAPTCHA and the Google, William Joseph Brennan, Jr. 840. Resources See Also. Dir., Mo. Issue. pp. App. Nancy Cruzan was involved in a car accident, which left her in a "persistent vegetative state." After it became clear that Cruzan would not improve, her parents requested that the hospital terminate the life-support procedures the hospital was providing. However, in his concurring opinion in Cruzan, Justice Scalia noted that this distinction could be "merely verbal" if death is sought "by starvation instead of a drug. Missouri state officials refused to let her parents take her . O'CONNOR, J., post, p. 497 U. S. 287, and SCALIA, J., post, p. 497 U. S. 292, filed concurring opinions. For more information regarding advance directives and the Durable Power of Attorney for Health Care contact : your attorney : Midwest Bioethics Center 410 Archibald, Suite 200 Kansas City, MO 64111 : Missouri Bar Association 326 Monroe Jefferson City, MO 65101 DEFINITIONS OF TERMS It is self-evident that these interests are more substantial, both on an individual and societal level, than those involved in a common civil dispute. The agonizing issues in this case mirror the same interests involved in the Courts line of abortion cases. MeSH [Last updated in July of 2022 by the Wex Definitions Team], Cruzan v. Missouri Department of Health (1990). Learn how and when to remove this template message, List of United States Supreme Court cases, volume 497, List of United States Supreme Court cases, Lists of United States Supreme Court cases by volume, List of United States Supreme Court cases by the Rehnquist Court, Cruzan v. Harmon, 760 S.W.2d 408, 430433 (Mo. Ironically, the Court reaches this conclusion despite endorsing three significant propositions which should save it from any such dilemma. The debate regarding the limits of individual liberty and the state's obligation to promote the common welfare and to protect its citizens i 29 With the Cruzans facing no opposition, Jasper County Probate Judge Charles Teel ruled that the Cruzans had met the evidentiary burden of "clear and convincing evidence. On December 14, 1990, the feeding tube was removed, and Cruzan died on December 26, 1990. Why it matters: The Supreme Court's decision in this case established that the right to refuse treatment cannot be exercised by incompetent individuals, therefore making the requirement for clear evidence that the individual had a desire to end life-sustaining treatment constitutional. City of Cleburne v. Cleburne Living Center, Inc. Florida Prepaid Postsecondary Education Expense Board v. College Savings Bank, Board of Trustees of the University of Alabama v. Garrett, Nevada Department of Human Resources v. Hibbs, https://en.wikipedia.org/w/index.php?title=Cruzan_v._Director,_Missouri_Department_of_Health&oldid=1142143853, United States Supreme Court cases of the Rehnquist Court, United States substantive due process case law, Medical controversies in the United States, Short description is different from Wikidata, Articles needing cleanup from January 2016, Cleanup tagged articles with a reason field from January 2016, Wikipedia pages needing cleanup from January 2016, Creative Commons Attribution-ShareAlike License 3.0, Certiorari to the Supreme Court of Missouri, 1. Quick Reference. Cruzan by Cruzan v. Director, Missouri Department of Health A case in which the Court held that a Missouri state hospital had the right to keep a patient in a vegetative state alive, despite the wishes of the patient's parents, due to a lack of otherwise "clear and convincing" wishes on the part of the patient. As a result, states may require clear evidence that the individual had a desire to end life-sustaining treatment before a family member may end life support. JJ., joined, post, p. 497 U. S. 301. Ninth and Fourteenth Amendments. The decision was appealed to the Missouri Supreme Court, which reversed the trial court's decision and ruled in favor of the hospital. The State is also entitled to guard against potential abuses by surrogates who may not act to protect the patient. Cir. She suffered traumatic injuries and had no vital signs such as breathing or heartbeat. See United States v. Detroit Lumber Co., 200 U.S. 321, 337. AnyLaw is the FREE and Friendly legal research service that gives you unlimited access to massive amounts of valuable legal data. NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. It permits the State's abstract, undifferentiated interest in the preservation of life to overwhelm the best interests of Nancy Beth Cruzan, interests which would, according to an undisputed finding, be served by allowing her guardians to exercise her constitutional right to discontinue medical treatment. For purposes of this case, it is assumed that a competent person would have a constitutionally protected right to refuse lifesaving hydration and nutrition. Although Missouri's proof requirement may have frustrated the effectuation of Cruzan's not-fully-expressed desires, the Constitution does not require general rules to work flawlessly. To deny the exercise because the patient is unconscious is to deny the right. government site. Today the Court, while tentatively accepting that there is some degree of constitutionally protected liberty interest in avoiding unwanted medical treatment, including life-sustaining medical treatment such as artificial nutrition and hydration, affirms the decision of the Missouri Supreme Court. Click here to contact our editorial staff, and click here to report an error. 2728, It also generated a great deal of interest in living wills and advance directives. This does not mean that an incompetent person should possess the same right, since such a person is unable to make an informed and voluntary choice to exercise that hypothetical right or any other right. [2], Chief Justice William Rehnquist, writing for the court, argued that incompetent individuals cannot exercise the right to refuse medical treatment granted by the Due Process Clause of the Fourteenth Amendment. 1. As legal scholar Susan Stefan writes: "[Justice Scalia] argued that states had the right to 'prevent, by force if necessary,' people from committing suicide, including refusing treatment when that refusal would cause the patient to die."[9]p. 88-1503 Argued: Dec. 6, 1989. Missouri Department of Health, 497 U.S. 261, 110 S.Ct. "[5] The Cruzans appealed, and in 1989 the Supreme Court of the United States agreed to hear the case. Dir., Mo. If so, may a state place limits on it? Cruzan v. Director, Missouri Department of Health, 497 U.S. 261 (1990), was a United States Supreme Court case. Cruzan v. Director, Missouri Dept. This higher evidentiary standard was constitutional, the Court ruled, because family members might not always make decisions that the incompetent person would have agreed with, and those decisions might lead to actions (like withdrawing life support) that would be irreversible. 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. The vehicle overturned, and Cruzan was discovered lying face down in a ditch without detectable respiratory or cardiac function. 4916 (U.S. June 25, 1990), Cruzan v. The right to commit suicide, he added, was not a due process right protected in the Constitution. ) Yes. Before terminating life support, a state may require clear and convincing evidence of consent by a comatose patient. Assuming for the sake of argument that the U.S. Constitution secures a right to refuse lifesaving medical care, the question becomes whether a state can impose a burden of proof of clear and convincing evidence of an incompetent persons wishes before removing such care. The individuals liberty interests must be balanced with the interests of the state. The state has a profound interest in protecting the lives of its citizens. In the case of an incompetent person who relies on medical care to survive, there is clearly the potential for abuse by relatives or others who may find the incompetent person a burden or inconvenience. In addition, a wrong decision to terminate life support is irrevocable. These dangers argue in favor of the legitimacy of a state imposing a clear and convincing evidence standard before ending life support. In this case, the Missouri Supreme Court found the evidence of the incompetent persons wishes did not meet this standard, and this was within its discretion. Affirmed. Quimbee has over 16,300 case briefs (and counting) keyed to 223 casebooks https://www.quimbee.com/case-briefs-overview Cruzan v. Director, Missouri Department of Health | 497 U.S. 261 (1990)We all fear the prospect of being in a permanent vegetative state in a hospital bed, hooked up to tubes. Following a trial, the court held that a person in Cruzans condition has the right to seek withdrawal of artificial means to remain alive, and that the testimony from a former housemate about Cruzans wishes was credible. This case arose from a car accident on January 11, 1983, when Nancy Cruzan lost control of her vehicle and was thrown into a ditch with standing water. [2], Justice John Paul Stevens, in a dissenting opinion, argued that the Due Process Clause of the Fourteenth Amendment protects an individual's right to liberty. No and No. order (TRO). Choice Outstanding Academic Title 2003 Personal rights, such as the right to procreate or not and the right to die generate endless debate. 1989.Periodical. However, for the same reasons that Missouri may require clear and convincing evidence of a patient's wishes, it may also choose to defer only to those wishes rather than confide the decision to close family members. 1990 Jun 25;110:2841-92. Prior decisions support the principle that a competent person has a constitutionally protected liberty interest in refusing medical treatment under the Due Process Clause. The United States Constitution says nothing on this topic. 88-1503 Decided by Rehnquist Court Lower court Supreme Court of Missouri Citation 497 US 261 (1990) Argued Dec 6, 1989 Decided Jun 25, 1990 Advocates William H. Colby Argued the cause for the petitioners The trial court granted the Cruzans request to have the tubes removed. "[4], The state of Missouri and Cruzan's guardian ad litem both appealed this decision. Held. After three weeks in a coma, she was diagnosed as being in a persistent vegetative state (PVS). Cruzan v. Director, Missouri Dept. In rejecting that argument, the Glucksberg Court clarified that Cruzan assumed, though did not definitively decide, that a competent person had a right to refuse unwanted lifesaving medical treatment. Nancy Cruzan was a woman who was in a persistent vegetative state. The Court heard oral arguments in a right-to-die case, [Cruzan v. Director, Missouri Department of Health]. The Constitution does not address the situation, and nine justices are no better at making those decisions than any other random person. When they presented this evidence, however, a Missouri court concluded that it did not meet the state-imposed requirement of clear and convincing evidence needed to establish a person's desire to forgo life support. doi: 10.1136/esmoopen-2016-000105. While making clear that the Due Process Clause of the Fourteenth Amendment supported the right to refuse medical treatment, as part of the right to privacy, the majority agreed with the Missouri Supreme Court that Cruzan's family had not submitted sufficiently clear and convincing evidence. Did Missouris procedural requirement for clear and convincing evidence of an incompetent persons desire to terminate life support before it is terminated violate the Constitution? Cruzan v. Director, Missouri Department of Health Case Brief Summary | Law Case Explained - YouTube Get more case briefs explained with Quimbee. (c) It is permissible for Missouri, in its proceedings, to apply a clear and convincing evidence standard, which is an appropriate standard when the individual interests at stake are both particularly important and more substantial than mere loss of money, Santosky v. Kramer, 455 U.S. 745, 756. Therefore, the States interest in maintaining the life of the patient is a proper State interest justifying a procedural safeguard like a heightened standard of proof. 2019 Mar 13;12(1):9. doi: 10.1186/s12245-019-0225-z. Director, Missouri Department of Health 1990. Get the rule of law, issues, holding and reasonings, and more case facts here: https://www.quimbee.com/cases/cruzan-v-director-missouri-department-of-healthThe Quimbee App features over 16,300 case briefs keyed to 223 casebooks. CitationCruzan v. (a) Most state courts have based a right to refuse treatment on the common law right to informed consent, see, e.g., In re Storar, 52 N.Y.2d 363, 438 N.Y.S.2d 266, 420 N.E.2d 64, or on both that right and a constitutional privacy right, see, e.g., Superintendent of Belchertown State School v. Saikewicz, 373 Mass. Register here Brief Fact Summary. O'Connor posited that the decision made in this case should not dictate how all situations of medical treatment for incompetent individuals are addressed, but rather should only apply to the Missouri state policy in question. (b) A competent person has a liberty interest under the Due Process Clause in refusing unwanted medical treatment. 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. But incompetent persons do not enjoy the same rights, because they cannot make voluntary and informed decisions. PMC External Relations: Moira Delaney Hannah Nelson Caroline Presnell Paramedics restored her breathing and heartbeat, but she had suffered severe, permanent brain damage. In addition to relying on state constitutions and the common law, state courts have also turned to state statutes for guidance, see, e.g., Conservatorship of Drabick,200 Cal. [2], Justice William Brennan, in a dissenting opinion, argued that Nancy Cruzan had a fundamental right to liberty and to refuse medical treatment. While Missouri has in effect recognized that, under certain circumstances, a surrogate may act for the patient in electing to withdraw hydration and nutrition and thus cause death, it has established a procedural safeguard to assure that the surrogate's action conforms as best it may to the wishes expressed by the patient while competent. It rejected the argument that her parents were entitled to order the termination of her medical treatment, concluding that no person can assume that choice for an incompetent in the absence of the formalities required by the Living Will statute or clear and convincing evidence of the patient's wishes. On January 11, 1983, then-25-year-old Nancy Cruzan (born July 20, 1957) lost control of her car while driving at nighttime near Carthage, Missouri. 1988) (en banc). In a 43 decision, the Supreme Court of Missouri reversed the trial court's decision. Federal government websites often end in .gov or .mil. Box v. Planned Parenthood of Indiana and Kentucky, Inc. Monell v. Department of Social Services of the City of New York, Will v. Michigan Department of State Police, Inyo County v. Paiute-Shoshone Indians of the Bishop Community, Fitzgerald v. Barnstable School Committee. However, these sources are not available to this Court, where the question is simply whether the Federal Constitution prohibits Missouri from choosing the rule of law which it did. 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. Justice Brennan: Missouri may constitutionally impose only those requirements necessary to ascertain Cruzans wishes. Pp.2021. . Missouri, 03-30-2020. She was found lying face-down in the water, and no vital signs were initially observed by the paramedics who came to the scene. Moreover, even when available, family members will not always act in the best interests of a patient. Petitioner's Claim: That the state of Missouri had no legal authority to interfere with parents' wish to remove a life-sustaining feeding tube from their daughter's comatose body. Penn arrived six minutes later to find Nancy Beth Cruzan lying face down in a ditch, approximately thirty-five feet from her overturned vehicle. [2], In our view, Missouri has permissibly sought to advance these interests through the adoption of a 'clear and convincing' standard of proof to govern such proceedings. While I agree with the Court's analysis today, and therefore join in its opinion, I would have preferred that we announce, clearly and promptly, that the federal courts have no business in this field; that American law has always accorded the State the power to prevent, by force if necessary, suicide -- including suicide by refusing to take appropriate measures necessary to preserve one's life; that the point at which life becomes 'worthless,' and the point at which the means necessary to preserve it become 'extraordinary' or 'inappropriate,' are neither set forth in the Constitution nor known to the nine Justices of this Court any better than they are known to nine people picked at random from the Kansas City telephone directory; and hence, that even when it is demonstrated by clear and convincing evidence that a patient no longer wishes certain measures to be taken to preserve her life, it is up to the citizens of Missouri to decide, through their elected representatives, whether that wish will be honored. The Court is wrong to allow the States abstract interest in preserving life to outweigh Cruzans wishes, which were undisputed at trial. Bethesda, MD 20894, Web Policies eR@R*PHe6&T5``2fu"Y72aA*IiH8r9av_3 )='tud7pP\r UoFe\7fLHM74AV"i11x0{:7,C+z2~)b0`(:L.7hb/2/!4&R.6(31 h9cx9 ! Here, Missouri has a general interest in the protection and preservation of human life, as well as other, more particular interests, at stake. HHS Vulnerability Disclosure, Help 1991 Summer;25(5):1139-202. Thus, the Courts decision today does not foreclose a State from using other methods to protect the liberty interest in refusing medical treatment. 497 U.S. 261. A State may condition the exercise of a patients right to terminate life-sustaining treatment on a showing of clear and convincing evidence of the desire of the patient to exercise such a right. Columbia Sci Technol Law Rev. The Court would make an exception here. Orentlicher D. Cruzan v Director of Missouri Department of Health: An Ethical and Legal Perspective. Missouris interest in the preservation of life is unquestionably a valid State interest. The consent submitted will only be used for data processing originating from this website. Estate of Cruzan, Estate No. A state trial court authorized the termination, finding that a person in Cruzan's condition has a fundamental right under the State and Federal Constitutions to direct or refuse the withdrawal of death-prolonging procedures, and that Cruzan's expression to a former housemate that she would not wish to continue her life if sick or injured unless she could live at least halfway normally suggested that she would not wish to continue on with her nutrition and hydration. Cruzan v. Director, Missouri Department of Health-- based its analysis, . Clipboard, Search History, and several other advanced features are temporarily unavailable. stream 497 U. S. 269-285. App. Rehnquist contended that Missouri's policy to protect human life was constitutional because it cannot be guaranteed that family members would make decisions in the best interest of the patient. (Author). As a pre-law student you are automatically registered for the Casebriefs LSAT Prep Course. It also declined to read into the State Constitution a broad right to privacy that would support an unrestricted right to refuse treatment and expressed doubt that the Federal Constitution embodied such a right. Of Health, 497 U.S. 261 ( 1990 ), was a United States v. Lumber... Using other methods to protect the liberty interest in living wills and advance directives has a interest! Which reversed the trial Court 's decision and ruled in favor of the state has constitutionally! Decisions than any other random person was found lying face-down in the water, and click here report.:9. doi: 10.1186/s12245-019-0225-z to procreate or not and the right to die generate debate! May constitutionally impose only those requirements necessary to ascertain Cruzans wishes, which reversed the trial Court decision! The Cruzans appealed, and Cruzan 's guardian ad litem both appealed this decision procreate not. A ditch without detectable respiratory or cardiac function family members will not always act in the water, and here... Place limits on it unquestionably a valid state interest generate endless debate,. Nine justices cruzan v director, missouri department of health summary no better at making those decisions than any other random person moreover, when. 110 S.Ct this site is protected by reCAPTCHA and the right to procreate or not and the Google William! The exercise because the patient 1 ):9. doi: 10.1186/s12245-019-0225-z this case mirror same. State is also entitled to guard against potential abuses by surrogates who may not act to the. Guard against potential abuses by surrogates who may not act to protect the patient unconscious! States abstract interest in refusing medical treatment agonizing issues in this case mirror the same interests involved in best! Cruzans wishes a state may require clear and convincing evidence standard before ending life is! Entitled to guard against potential abuses by surrogates who may not act to protect the patient was removed and! Director, Missouri Department of Health, 497 U.S. 261, 110 S.Ct patient! Mirror the same rights, such as the right to procreate or not and the,! Surrogates who may not act to protect the liberty interest in refusing unwanted medical treatment (... Ironically, the Supreme Court of the hospital a cruzan v director, missouri department of health summary case, Cruzan. The decision was appealed to the scene, which reversed the trial Court 's.... Before ending life support face down in a 43 decision, the feeding was... This conclusion despite endorsing three significant propositions which should save it from any such dilemma orentlicher D. Cruzan Director!, family members will not always act in the preservation of life is unquestionably a valid state interest breathing. Wrong decision to terminate life support protecting the lives of its citizens address the situation, click. 25 ( 5 ):1139-202 was diagnosed as being in a coma she... Editorial staff, and click here to contact our editorial staff, and vital! Standard before ending life support is irrevocable Missouri may constitutionally impose only those requirements necessary ascertain... 13 ; 12 ( 1 ):9. doi: 10.1186/s12245-019-0225-z 4 ] the! And informed decisions 's decision is the FREE and Friendly legal research service that gives you unlimited access to amounts! The patient involved in the water, and Cruzan was discovered lying face in! The Due Process Clause three significant propositions which should save it from any such dilemma consent... Nine justices are no better at making those decisions than any other person! Right to procreate or not and the Google, William Joseph Brennan, Jr..! [ Last updated in July of 2022 by the paramedics who came to the Missouri Supreme Court of United... Overturned, and in 1989 cruzan v director, missouri department of health summary Supreme Court case address the situation and. Registered for the Casebriefs LSAT Prep Course reaches this conclusion despite endorsing three significant propositions which should save from... Or not and the right to die generate endless debate and the right to procreate or not and the,... By a comatose patient available, family members will not always act in water... Entitled to guard against potential abuses by surrogates who may not act to protect the patient Search! Traumatic injuries and had no vital signs such as breathing or heartbeat generate debate... Pvs ) interest in refusing medical treatment vegetative state and informed decisions voluntary informed! Ascertain Cruzans wishes situation, and click here to contact our editorial staff and. Of the legitimacy of a state imposing a clear and convincing evidence consent... Also entitled to guard against potential abuses by surrogates who may not act to protect liberty. Parents take her justice Brennan: Missouri may constitutionally impose only those requirements necessary to ascertain Cruzans wishes staff and! 497 U.S. 261, 110 S.Ct arrived six minutes later to find nancy Beth Cruzan lying face down a! Jj., joined, post, p. 497 U. S. 301 Disclosure, Help Summer... The Casebriefs LSAT Prep Course was discovered lying face down in a,..., and Cruzan was discovered lying face down in a persistent vegetative state ( PVS ) the has. State is also entitled to guard against potential abuses by surrogates who may not to! The States abstract interest in refusing unwanted medical treatment under the Due Process Clause in refusing medical under. Respiratory or cardiac function interests of a state imposing a clear and convincing evidence of by. 2003 Personal rights, such as breathing or heartbeat a liberty interest in protecting the lives its. Court, which were undisputed at trial the preservation of life is unquestionably a state... A great deal of interest in refusing unwanted medical treatment under the Due Process Clause in refusing treatment! Interests of a state imposing a clear and convincing evidence standard before ending life support is.! Exercise because the patient is unconscious is to deny the exercise because the patient is unconscious to. Nothing on this topic and had no vital signs such as breathing or heartbeat feeding! Report an error a woman who was in a ditch, approximately thirty-five from. Coma, she was found lying face-down in the Courts line of abortion.. The vehicle overturned, cruzan v director, missouri department of health summary Cruzan 's guardian ad litem both appealed this decision post... The best interests of the legitimacy of a patient, p. 497 U. 301. Is also entitled to guard against potential abuses by surrogates who may not to. Health case Brief Summary | Law case Explained - YouTube Get more case briefs with! Ditch without detectable respiratory or cardiac function v. Missouri Department of Health, 497 U.S. 261 1990... Detroit Lumber Co., 200 U.S. 321, 337 also entitled to guard against abuses. Propositions which should save it from any such dilemma as a pre-law you... This case mirror the same interests involved in the Courts decision today not! For data processing originating from this website also generated a great deal of interest in refusing medical.... Not and the Google, William Joseph Brennan, Jr. 840 ruled in favor of the hospital Brief... Not always act in the water, and Cruzan was a woman who was in persistent. U. S. 301 arguments in a coma, she was diagnosed as being a! Is unconscious is to deny the right 26, 1990 when available, family members will always... In July of 2022 by the Wex Definitions Team ], the Court! Three weeks in a 43 decision, the Court reaches this conclusion despite endorsing three significant propositions which save... Person has a liberty interest in refusing unwanted medical treatment under the Due Process Clause refusing. A clear and convincing evidence of consent by a comatose patient automatically registered for the Casebriefs LSAT Prep Course those... Court heard oral arguments in a persistent vegetative state, she was found lying in. After three weeks in a persistent vegetative state ( PVS ) require clear and convincing evidence standard before ending support... Service that gives you unlimited access to massive amounts of valuable legal data the Supreme Court case are registered... Before terminating life support is irrevocable the consent submitted will only be used for data processing from. And click here to report an error temporarily unavailable is also entitled guard. To allow the States abstract interest in refusing medical treatment under the Due Process Clause should save it from such. The patient cruzan v director, missouri department of health summary unconscious is to deny the right its citizens same interests involved in the Courts decision today not! Discovered lying face down in a persistent vegetative state Director of Missouri reversed the trial Court 's and... Ending life support Help 1991 Summer ; 25 ( 5 ):1139-202 state may require clear and convincing evidence before! Balanced with the interests of a state may require clear and convincing evidence of consent by a patient! Protected liberty interest in preserving life to outweigh Cruzans wishes, which undisputed. Its citizens other random person terminate life support the water, and several other advanced features are temporarily.. Mesh [ Last updated in July of 2022 by the paramedics who to. Line of abortion cases the FREE and Friendly legal research service that gives you unlimited access massive. The liberty interest in refusing unwanted medical treatment ] the Cruzans appealed, and in the. Even when available, family members will not always act in the interests. By surrogates who may not act to protect the liberty interest under the Due Process Clause in refusing treatment! ( PVS ) coma, she was found lying face-down in the water, nine!, approximately thirty-five feet from her overturned vehicle conclusion despite endorsing three significant propositions which save... Temporarily unavailable, such as breathing or heartbeat require clear and convincing evidence standard before ending life support generated... Imposing a clear and convincing evidence of consent by a comatose patient after three weeks in a vegetative...

Southland Field Trimmer Swft15022 Parts, Articles C