Missouris rule prohibiting the termination of life support to permanently comatose patients without clear and convincing evidence of consent by the patient was challenged as unconstitutional. 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. Completion rate of physician orders for life-sustaining treatment for patients with metastatic or recurrent cancer: a preliminary, cross-sectional study. The decision in this case established that states' interest in preserving life may outweigh the right to refuse medical treatment, but ultimately determined that it is up to the states to decide what evidentiary requirements should be in place.[2]. Quick Reference. A State may constitutionally require evidence of an incompetent patients wishes by clear and convincing evidence before removing life support. Continue with Recommended Cookies, Following is the case brief for Cruzan v. Director, Missouri Dept. 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. Some people in that situation would want doctors to withhold treatment and let nature take its course. "[4] The court ruled that Cruzan had effectively 'directed' the withdrawal of life support by telling a friend earlier that year that if she were sick or injured, "she would not wish to continue her life unless she could live at least halfway normally. Click here to contact our editorial staff, and click here to report an error. Cruzan v. Director, Missouri Department of Health is a case decided on June 25, 1990, by the United States Supreme Court holding that a state may require clear evidence of an individual's desire to end life-sustaining treatment before a family may be permitted to end life support. Show Summary Details. `0Xca j6Fq 4^FQ?8lp I%2c8DZ0R"i0F" [2], Justice William Brennan, in a dissenting opinion, argued that Nancy Cruzan had a fundamental right to liberty and to refuse medical treatment. 29 Six years later, on August 17, 1996, he killed himself. 1991 May 15;114(10):895-901. doi: 10.7326/0003-4819-114-10-895. We and our partners use cookies to Store and/or access information on a device. (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. ) The right to refuse medical treatment flows from liberty interests against involuntary invasions of bodily integrity. Also, it should be emphasized that the Court today does not address the role of a surrogate decision-maker. Cruzan v. Director, Missouri Department of Health is a case decided on June 25, 1990, by the United States Supreme Court holding that a state may require clear evidence of an individual's desire to end life-sustaining treatment before a family may be permitted to end life support. T No and No. The United States Supreme Court addressed these issues in Cruzan versus Director, Missouri Department of Health. 2258. A significant outcome of the case was the creation of advance health directives. Justice John Paul Stevens also wrote a dissenting opinion. doi: 10.1136/esmoopen-2016-000105. 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. certiorari to the supreme court of missouri No.881503. Stevens posited that a guardian should be able to make decisions on behalf of an incompetent individual to ensure that the treatment she is receiving is in her best interest. Dept of Health, 497 U.S. 261, 110 S. Ct. 2841, 111 L. Ed. 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. Chief Justice William Rehnquist delivered the opinion of the court, joined by Justices Byron White, Sandra Day O'Connor, Antonin Scalia, and Anthony Kennedy. The court then decided that the State Living Will statute embodied a state policy strongly favoring the preservation of life, and that Cruzan's statements to her housemate were unreliable for the purpose of determining her intent. Submit your questions and get answers from a real attorney here: https://www.quimbee.com/cases/cruzan-v-director-missouri-department-of-healthDid we just become best friends? The .gov means its official. 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Cruzan v. Director, Missouri Department of Health: Summary When Nancy's parents could not obtain the consent of the hospital to remove her feeding tube, they sued the Missouri Department of. of Health: In 1983, Nancy Cruzan was in a car accident. It found that Cruzan's stray statements throughout the course of her life were not sufficiently specific to conclude that she would not want medical treatment or the feeding tube. "Constitution of the United States: Amendments 11-27", "Cruzan by Cruzan v. Director, Missouri Department of Health: Oral Argument December 06, 1989 [Transcript]", "Cruzan by Cruzan v. Director, Missouri Department of Health", "Nancy Cruzan Dies, Outlived by a Debate Over the Right to Die", "Lester Cruzan Is Dead at 62; Fought to Let His Daughter Die", Living Wills and Advance Directives for Medical Decisions, Schloendorff v. Society of New York Hospital, Moore v. Regents of the University of California, Medical Experimentation on Black Americans, Greenberg v. Miami Children's Hospital Research Institute. 497 U. S. 280-285. 2019 Oct 22;18(1):84. doi: 10.1186/s12904-019-0475-9. 497 U. S. 280-285, (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, 455 U. S. 756. After three weeks in a coma, she was diagnosed as being in a persistent vegetative state (PVS). Here, the Court decided thatwhile competent individuals had the right to stop or refuse medical treatmentunder theDue Process Clause, the circumstances were different for incompetent individuals. (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. 6 B6+}TN':73C: #|&Ch:NrIJZ!l@;@6H7 s\4GC=$Sx[]CH!QB$M29D3JD0 ; 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. Please enable it to take advantage of the complete set of features! - Legal Principles in this Case for Law Students. 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. The State may also properly decline to make judgments about the "quality" of a particular individual's life and simply assert an unqualified interest in the preservation of human life to be weighed against the constitutionally protected interests of the individual. 1991 Summer;25(5):1139-202. "[13], Justice Scalia argued that refusing medical treatment, if doing so would cause a patient's death, was equivalent to the right to commit suicide. Yet, the Court should not be in the business of making choices as to when a life is worthless, or when it is time for extraordinary measures to cease in keeping a patient alive. STEVENS, J., filed a dissenting opinion, post, p. 497 U. S. 330. Cruzan v. Missouri Department of Health (1990)is an important United States Supreme Court case involving an incompetent young adult and the right to die.This case was the first"right to die"case heard by the Supreme Court. This book maps out the legal, political, and ethical issues swirling around personal rights. Argued December 6, 1989 Decided June 25, 1990 Rehnquist, C.J., delivered the opinion of the Court, in which White, O'Connor, Scalia, and Kennedy, JJ., joined. . The Understanding Law Video Lecture Series: Monthly Subscription ($19 / Month) Cruzan v. Director, Missouri Department of Health, 497 U.S. 261 (1990), was a United States Supreme Court case. Before terminating life support, may a state may require clear and convincing evidence of consent by a comatose patient? Register here Brief Fact Summary. 728, 370 N.E.2d 417. Nor does it prevent States from developing other approaches for protecting an incompetent individual's liberty interest in refusing medical treatment. Her parents seek the right to withhold food . 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 held that Cruzans wishes were not proven by clear and convincing, The U.S. Supreme Court affirmed the Missouri Supreme Courts decision, holding that the States interest in preserving life must be balanced against an. Every Bundle includes the complete text from each of the titles below: PLUS: Hundreds of law school topic-related videos from O'Connor, J., and Scalia, J., filed concurring opinions. The refusal of artificial means of staying alive is a protected liberty interest. Rptr. Howard Ball shows how the Supreme Court has grappled with the right to reproduce and to abort, and takes on the issue of auto-euthanasia and assisted suicide, from . In Justice OConnors view, such a duty may well be constitutionally required to protect ones liberty interest in refusing medical treatment. Because she was in a persistent vegetative state with no significant cognitive function, she required hydration and feeding tubes to live. No proof is required to show an incompetent person would wish to continue treatment. MeSH 497 U.S. 261, 110 S. Ct. 2841, 111 L. Ed. of Health is a landmark case because it gave strong deference to a State's interest in the preservation of life when balancing that interest against the wishes of an incompetent patient to remove life support. The first "right to die" case ever heard by the Court, Cruzan was argued on December 6, 1989, and decided on June 25, 1990. 2. Petitioner Nancy Cruzan is incompetent, having sustained severe injuries in an automobile accident, and now lies in a Missouri state hospital in what is referred to as a persistent vegetative state: generally, a condition in which a person exhibits motor reflexes but evinces no indications of significant cognitive function. [6] The Due Process Clause provides: "[N]or shall any State deprive any person of life, liberty, or property, without due process of law[.]"[7]. Cruzan v. Director, Missouri Department of Health-- based its analysis, . Policy: Christopher Nelson Caitlin Styrsky Molly Byrne Jimmy McAllister Samuel Postell Holding: Yes. Reflecting the controversiality of the "end of life" issue, five Justices wrote separate opinions about the case. Does a State law that requires a patients family to prove the patients wishes to remove artificial means to sustain life by clear and convincing evidence violate the Constitution? An erroneous decision not to terminate results in a maintenance of the status quo, with at least the potential that a wrong decision will eventually be corrected or its impact mitigated by an event such as an advancement in medical science or the patient's unexpected death. Ballotpedia features 407,502 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. v. DIRECTOR, MISSOURI DEPARTMENT OF HEALTH, et al. address. Before terminating life support, a state may require clear and convincing evidence of consent by a comatose patient. It left it to the states to determine their own right-to-die standards, rather than creating a uniform national standard. Front Cardiovasc Med. Synopsis of Rule of Law. CitationCruzan v. Stay connected to Quimbee here: Subscribe to our YouTube Channel https://www.youtube.com/subscription_center?add_user=QuimbeeDotComQuimbee Case Brief App https://www.quimbee.com/case-briefs-overview Facebook https://www.facebook.com/quimbeedotcom/ Twitter https://twitter.com/quimbeedotcom #casebriefs #lawcases #casesummaries However, the question whether that constitutional right has been violated must be determined by balancing the liberty interest against relevant state interests. Missouris interest in the preservation of life is unquestionably a valid State interest. CRUZAN, by her parents and co-guardians, CRUZAN et ux. The clear and convincing evidence standard also serves as a societal judgment about how the risk of error should be distributed between the litigants. 2019 Fall;21(1):114-181. The majority opinion, as I read it, would affirm that decision on the ground that a State may require 'clear and convincing' evidence of Nancy Cruzan's prior decision to forgo life-sustaining treatment under circumstances such as hers in order to ensure that her actual wishes are honored. Every Bundle includes the complete text from each of the titles below: PLUS: Hundreds of law school topic-related videos from The hospital refused to do so without a court order. It ruled that no one may refuse treatment for another person, absent an adequate living will "or the clear and convincing, inherently reliable evidence absent here. Register here Brief Fact Summary. (Rehnquist, C.J. The majority also dismissed the notion that family members would be able to substitute their own judgment for an individual patient's judgment unless they could clearly show that the patient shared their views. The Cruzans filed a lawsuit in state court seeking authorization to remove the tubes. Moreover, even when available, family members will not always act in the best interests of a patient. On the night of January 11, 1983, Nancy Cruzan lost control of her car as she traveled down Elm Road in Jasper County, Missouri. The majority opinion specifically rejected a constitutional right of family members to terminate care for patients whose wishes are not known. The parents of Nancy Cruzan, a Missouri woman in a persistent vegetative state, petitioned to be allowed to order the termination of her artificially administered hydration and nutrition. [14] For example, just one month after the Supreme Court ruling in Cruzan, the Society for the Right to Die had received some 300,000 requests for advance directive forms. Clipboard, Search History, and several other advanced features are temporarily unavailable. 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. Cruzan v. Director, Missouri Department of Health in the . "[4], The state of Missouri and Cruzan's guardian ad litem both appealed this decision. 1. 2d 224, 1990 U.S. Cruzan v. Director, MDH, 497 U.S. 261 (1990) Cruzan by Cruzan v. Director, Missouri Department of Health No. Director, Missouri Department of Health 1990. 8600 Rockville Pike eCollection 2022. 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 court then decided that the State Living Will statute embodied a state policy strongly favoring the preservation of life, and that Cruzan's statements to her housemate were unreliable for the purpose of determining her intent. Cruzan v. Director, Missouri Department of Health. 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? Mullane v. Central Hanover Bank & Trust Co. Cleveland Board of Education v. Loudermill, Cruzan v. Director, Missouri Department of Health, Cumming v. Richmond County Board of Education, Sipuel v. Board of Regents of the University of Oklahoma, Davis v. County School Board of Prince Edward County, Griffin v. County School Board of Prince Edward County, Green v. County School Board of New Kent County, United States v. Montgomery County Board of Education, Alexander v. Holmes County Board of Education, Swann v. Charlotte-Mecklenburg Board of Education. Justice Brennan: Missouri may constitutionally impose only those requirements necessary to ascertain Cruzans wishes. Village of Arlington Heights v. Metropolitan Housing Development Corp. Regents of the University of California v. Bakke, Crawford v. Los Angeles Board of Education, Board of Education of Oklahoma City v. Dowell, Northeastern Fla. Chapter, Associated Gen. 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. Quimbee has over 16,300 case briefs. The vehicle overturned, and Cruzan was discovered lying face down in a ditch without detectable respiratory or cardiac function. Santa Clara County v. Southern Pacific Railroad Co. Harper v. Virginia State Board of Elections, San Antonio Independent School District v. Rodriguez, Massachusetts Board of Retirement v. Murgia, New York City Transit Authority v. Beazer. The issue here is whether the Constitution prohibits Missouri from having a clear-and-convincing evidentiary standard before removing life support for an incompetent patient. Cruzan v. Director, Missouri Department of Health United States Supreme Court 497 U.S. 261, 110 S.Ct. U.S. Supreme CourtCruzan v. Director, MDH, 497 U.S. 261 (1990), Cruzan by Cruzan v. Director, Missouri Department of Health. These questions should be left to the states. Cruzan v. Director, Missouri Department of Health Citation. 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. Similarly, it is entitled to consider that a judicial proceeding regarding an incompetent's wishes may not be adversarial, with the added guarantee of accurate factfinding that the adversary process brings with it. PMC 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. an individual and societal level, than those involved in a common civil dispute. v. Varsity Brands, Inc. If so, may a state place limits on it? An erroneous decision not to terminate results in a maintenance of the status quo, with at least the potential that a wrong decision will eventually be corrected or its impact mitigated by an event such as an advancement in medical science or the patient's unexpected death. 2d 224, 1990 U.S. LEXIS 3301, 58 U.S.L.W. BRENNAN, J., filed a dissenting opinion, in which MARSHALL and BLACKMUN. The case was decided on June 25, 1990. The Supreme Court's decision on Cruzan v. Director, Missouri Department of Health is one of landmark Supreme Court cases, and for good reason. 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. It may legitimately seek to safeguard the personal element of an individual's choice between life and death. %PDF-1.2 Cruzan v. Director, Missouri Department of Health in The Oxford Guide to . Kim JW, Choi JY, Jang WJ, Choi YJ, Choi YS, Shin SW, Kim YH, Park KH. Beyond the Cruzan case: the U.S. Supreme Court and medical practice. Author U.S. Supreme Court PMID: 12041283 Abstract KIE: 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. To deny the exercise because the patient is unconscious is to deny the right. Cruzan v. Director Missouri Department of Health. [2], Cruzan's case had attracted national interest, and right-to-life activists and organizations filed seven separate petitions with the court asking to resume feeding, but were found to have no legal standing for intervention. 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. Missouri's rule prohibiting the termination of life support to permanently comatose patients without clear and convincing evidence of consent by the patient Respondent: Director, Missouri Department of Health. Her family wanted to stop life support treatments so she could die. 10 0 obj The State is bearing the cost of her care. 2. The Missouri Supreme Court is affirmed. Issue. It is quite impossible (because the Constitution says nothing about the matter) that those citizens will decide upon a line less lawful than the one we would choose; and it is unlikely (because we know no more about 'life-and-death' than they do) that they will decide upon a line less reasonable. The Supreme Court thus decided whether the State of Missouri was violating theDue Process Clauseof theFourteenth Amendmentby refusing to remove the Cruzans daughter from life support. An official website of the United States government. Columbia Sci Technol Law Rev. As is evident from the Court's survey of state court decisions. Here, Missouri has a general interest in the protection and preservation of human life, as well as other, more particular interests, at stake. The first "right to die" case ever heard by the Court, Cruzan was argued on December 6, 1989, and decided on June 25, 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. The right to terminate life-sustaining treatment of an incompetent, if it is to be exercised, must be done for such incompetent by a surrogate. 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. Ct., Jasper County, Mo., July 27, 1988). A car accident left Ms. Cruzan in a coma. The vehicle overturned, and Cruzan was discovered lying face down in a ditch without detectable respiratory or cardiac function. The U.S. Supreme Court granted certiorari. Email Address: Please check your email and confirm your registration. The due process right of refusal of treatment is different for incompetent patients, because it is unclear what an incompetent patient wants. 2841 (1990) Facts Nancy Cruzan (plaintiff) was involved in a serious automobile accident. Estate of Cruzan, Estate No. 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 ! 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. The accident left her in a persistent vegetative state, whereby she would exhibit some motor reflexes but had no indication of brain function. This type of case, where a person requests that her life be left to natural processes, must be distinguished from cases that involve assisted suicide, whereby a doctor will take an affirmative step to induce a persons death. Although recognizing the right to withhold medical treatment, the court found that Nancys statements to her roommate didnt establish by clear and convincing evidence that Nancy wished to withhold life-sustaining medical treatment.Cruzans parents successfully petitioned the United States Supreme Court to review Nancys case. KIE: MLA citation style: Rehnquist, William H, and Supreme Court Of The United States. of Health Case Brief. 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. government site. 2. Hospital employees refused, without court approval, to honor the request of Cruzan's parents, copetitioners here, to terminate her artificial nutrition and hydration, since that would result in death. A state trial court's authorization of the termination was reversed by the Missouri Supreme Court, which ruled that no one may order an end to life sustaining treatment for an incompetent patient in the absence of a valid living will or clear and convincing evidence of the patient's wishes. 4916 (U.S. June 25, 1990). https://www.quimbee.com/case-briefs-overview Have Questions about this Case? Rptr. Cruzan v. Director, Missouri Department of Health, 497 U.S. 261 (1990), was a landmark decision of the Supreme Court of the United States involving a young adult incompetent. The dissenting justices, led by now-retired Justice Brennan, treat Nancy Cruzan as a dead person who has slipped through the cracks in the usual medical tests for death. Court 497 U.S. 261, 110 S. Ct. 2841, 111 L. Ed: MLA style! Accident left Ms. Cruzan in a coma it is unclear what an incompetent person would to! 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And confirm your registration exercise because the patient is unconscious is to the! Hydration and feeding tubes to live required hydration and feeding tubes to live Ms. Cruzan in persistent... With Recommended Cookies, Following is the case people in that situation want... Legal, political, and ethical issues swirling around personal rights emphasized that the Court 's survey state... Of an incompetent patient family members will not always act in the Oxford Guide to County,,. As a societal judgment about how the risk of error should be emphasized that the Court today not... Answers from a real attorney here: https: //www.quimbee.com/cases/cruzan-v-director-missouri-department-of-healthDid we just become best friends YJ Choi! Some people in that situation would want doctors to withhold treatment and let nature take course... Missouri Dept the tubes a protected liberty interest policy: Christopher Nelson Styrsky... Issue, five Justices wrote separate opinions about the case was decided on June 25 1990. Remove the tubes, cross-sectional study creating a uniform national standard our professional staff of editors writers. Error should be distributed between the litigants is evident from the Court today does not the... Such a duty may well be constitutionally required to protect ones liberty interest in the best interests of patient... Christopher Nelson Caitlin Styrsky Molly Byrne Jimmy McAllister Samuel Postell Holding:.! Health directives so, may a state may require clear and convincing evidence of an individual 's choice life! State is bearing the cost of her care obj the state is bearing the cost of her.... Brain function Cruzan was discovered lying face down in a ditch without detectable respiratory or cardiac function Cookies. A common civil dispute `` [ 4 ], the state is bearing the cost of care. Is required to protect ones liberty interest in refusing medical treatment flows from liberty interests against involuntary invasions bodily! Risk of error should be distributed between the litigants later, on August 17, 1996, he himself. '' issue, five Justices wrote separate opinions about the case was the creation of Health. Editors, writers, and Supreme Court of the complete set of features incompetent person would to. Refusal of artificial means of staying alive is a protected liberty interest the. Alive is a protected liberty interest Cruzan 's guardian ad litem both appealed this decision constitutionally require of. Opinion specifically rejected a constitutional right of refusal of artificial means of staying alive a! Removing life support, a state may require clear and convincing evidence of consent by a comatose patient //www.quimbee.com/cases/cruzan-v-director-missouri-department-of-healthDid. Members will not always act in the preservation of life '' issue, five Justices separate... 1991 may 15 ; 114 ( 10 ):895-901. doi: 10.1186/s12904-019-0475-9 Cookies. 110 S.Ct of bodily integrity County, Mo., July 27, 1988 ),.
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