Right to Die: Euthanasia

Sonya HuJunior DivisionHistorical Paper

Late in the night of January 20, 1936, Lord Dawson of Penn, Englands royal physician, injected King George V with fatal doses of morphine and cocaine as he lay comatose on his deathbed. The King was urged gently towards his death and the end of his constant suffering. The next morning, his passing was announced in The Times headline as a peaceful ending at midnight.[footnoteRef:1] The King had been in failing health for several months. Days before the Kings death, Queen Mary had sent for the physician and asked that he ease her spouses anguish. Lord Dawson believed that waiting for the mechanical end when all that is really life has departed[footnoteRef:2] would only exhaust the onlookers and keep them so strained that they [could not] avail themselves to the solace of thought, communion, or prayer;[footnoteRef:3] thus leading to his decision to determine the end[footnoteRef:4] on his own. So, at approximately eleven oclock that night, while accompanied by the Archbishop of Canterbury, the royal physician sped the Kings death by introducing two lethal injections. By hastening the Kings passing, rather than taking great measures to preserve his life, Dawson allowed the King to end his suffering and die with peace and the dignity and serenity which he so richly merited.[footnoteRef:5] When his intervention was revealed in 1986, controversy surrounded it, as it raised the question of whether it had been morally and ethically correct for the physician to administer the medicament. [1: Lelyveld, Joseph. 1936 Secret Is Out: Doctor Sped George Vs Death. The New York Times. The New York Times, 28 Nov. 1986. Web. 29 Nov. 2013. .] [2: (Dawson qtd. in Ramsay, page 1)] [3: Ibid 1.] [4: Ibid 1.] [5: Ibid 1.]

There is a single word that summarizes this cessation of pain and dying in peace euthanasia, meaning good death in Greek. As it plays an essential role in ending the pain of those who are suffering, as well as easing the emotional strains upon the family of the affected party, many argue, as I would like to argue here, that euthanasia should be a right granted to terminally ill patients who are suffering and no longer have the will to live.Euthanasia has been practiced throughout history, as far back as ancient Greece and Rome, where people were tolerant of euthanasia and suicide. In Sparta, for example, male infants with signs of disability or sickliness were led to their deaths.[footnoteRef:6] This was viewed as both a way to protect society from unnecessary albatross and to save the children from the burden of existence. This mentality was adopted throughout ancient Greece and Rome. The Hippocratic Oath, a pledge taken by physicians to vow that they would practice medicine honestly, prohibited doctors from either giving or suggesting a deadly poison to anybody, not even if asked for. [footnoteRef:7] However, few ancient Greek and Roman physicians adhered to the Oath; possibly due to its initial ill reception, as it had only represented a small fraction of the Greek opinion at the time.[footnoteRef:8] However, the ascendancy of Christianity, with its views that life is a gift from God, and the fifth of the eminent Ten Commandments, which states that thou shalt not kill, reinforced the Hippocratic Oath, causing many to oppose euthanasia.[footnoteRef:9] As a result, the practice faded away during the twelfth through fifteenth centuries. Then, in the seventeenth century, Renaissance and Reformation writers began to challenge the churchs authoritative teachings on all matters, including euthanasia and suicide, and the practices became acceptable again.[footnoteRef:10] However, by the late eighteenth century, with the rise of the Second Great Awakening, the temporary toleration of euthanasia and suicide during the Enlightenment disappeared once more. [6: Dowbiggin, Ian Robert. A Merciful End: The Euthanasia Movement in Modern America. Oxford: Oxford UP, 2003. Print.] [7: Tyson, Peter. The Hippocratic Oath Today. PBS. PBS, 27 Mar. 2001. Web. 19 Jan. 2014. .] [8: "The Hippocratic Oath."BBC News. BBC, 20 Nov. 2003. Web. 12 May 2014. .] [9: Manning, Michael. Euthanasia and Physician-Assisted Suicide: Killing or Caring? New York: Paulist, 1998. Print.] [10: Ibid 10.]

In the late 1870s, Samuel Williams, a non-physician often credited as the first modern supporter of the practice, attempted to revive euthanasia again when he began to publically advocate the use of morphine and chloroform to both alleviate terminal pain and intentionally end the patients life. His proposal received a great deal of attention in medical journals and at scientific meetings, but lost popularity after the Journal of the American Medical Association described it as an attempt to make the physician don the robes of an executioner.[footnoteRef:11] [11: Ibid 11.]

The public support for euthanasia slowly began to gain popularity once again during the early twentieth century. Several bills to legalize euthanasia were proposed; although they failed, the bills were a sign of the emerging interest in the practice. In an opinion poll in 1937, 53% of Americans answered that they approved of euthanasia.[footnoteRef:12] This progression of acceptance was abruptly halted when the public learned of the Nazis Action T-4. The Nazis use of involuntary euthanasia, or mercy killings,[footnoteRef:13] to terminate the life of mentally ill patients and handicapped children changed the American and European publics perception of euthanasia. The euthanasia movement found itself on the defensive and was constantly forced to deny that the form of euthanasia it supported was the same as the Nazis murder. In 1950, only 36% of Americans answered that they approved of euthanasia in the same opinion poll that was asked in 1937.[footnoteRef:14] Despite the movements efforts, the practice fell from the public favor and all but disappeared after World War II. However, the right-to-die debate had not died completely; examination of court cases in the last forty years can shed light on its current revival. [12: Dowbiggin 32.] [13: Ibid 61.] [14: Ibid 33.]

Euthanasia has two variations: passive and active. Unlike the active examples of Lord Dawson administering a lethal drug or the ancient Greek and Roman physicians providing their patients with a deadly poison,[footnoteRef:15] passive euthanasia is, simply put, letting someone die, and is commonly associated with the cessation of life-sustaining medical treatment or equipment. Two famous lawsuits that reintroduced the contentious issue and reshaped the public opinion of passive euthanasia are re Quinlan 70 N.J. 10 (1976) 355 A.2d 647 and Cruzan v. Director [Missouri Department of Health]. [15: Tyson 1.]

The first to occur was the 1976 case of re Quinlan. After taking a combination of tranquilizer pills and alcohol, Karen Ann Quinlan stopped breathing for two fifteen minute periods. She was hurriedly transported to a hospital, but by the time she arrived, she had already suffered permanent brain damage and was declared to have fallen into a persistent vegetative state with no prospect of recovery.[footnoteRef:16] Karen Anns parents privately requested that the doctors caring for their daughter disconnect her respirator so that she could die with grace and dignity.[footnoteRef:17] Their request refused, they took their case to the New Jersey Supreme Court. There, Paul W. Armstrong, the Quinlans lawyer, argued that keeping Karen Ann alive after the dignity, beauty, promise, and meaning of earthly life have vanished was a cruel and unusual punishment that violated the Eighth Amendment of the U.S. Constitution.[footnoteRef:18] Armstrong then further broadened his argument and pushed for a constitutional right to die based on the rights of freedom of religion, privacy, and self-determination. As such a petition had never been filed, the Quinlan case quickly captured the attention of the public, and became the motivation for the rapid expansion of the euthanasia movement. Finally, the New Jersey Supreme Court, recognizing Karen Ann Quinlans right to die, decided unanimously that she could be disconnected from her respirator as long as the medical authorities saw no reasonable possibility that she would recover.[footnoteRef:19] The Court also declared that no one would be held criminally liable for her death, because it would not be homicide, but rather expiration from existing natural causes.[footnoteRef:20] At her passing, Dr. James Wolf, the internist who had cared for Karen Ann, commented that no attempt was made to revive her, on the advice of the family. They felt it was inappropriate. She died unmolested, a natural death, simply witnessed.[footnoteRef:21] [16: McFadden, Robert D. Karen Ann Quinlan, 31, Dies; Focus of 76 Right To Die Case. The New York Times. The New York Times, 12 June 1985. Web. 24 Dec. 2013. .] [17: Ibid 1.] [18: Ibid 3.] [19: Ibid 1.] [20: Ibid 1.] [21: Ibid 1.]

A second case, similar to Karen Ann Quinlans, occurred in Missouri just seven years after the New Jersey Supreme Courts ruling. Nancy Cruzan was discovered barely alive after losing control of her car and crashing. She, too, fell into a persistent vegetative state with no chance of recovery.[footnoteRef:22] After the hospital refused their request to remove Nancys medically-assisted nutrition and hydration, her parents filed a declaratory judgment action to the Missouri Supreme Court, but once again, their request was denied. The Cruzans took their lawsuit to the U.S. Supreme Court. A crucial argument was that Nancy had previously told her housemate that if she were sick or injured, she did not want to continue her life unless she could live at least halfway normally, suggesting that she would not want to live in her current condition. In December 1990, the Cruzans persuaded the U.S. Supreme Court that the clear and convincing evidence that they sought did exist, and in a five-to-four decision, the Court allowed Nancy to be removed from life support.[footnoteRef:23] [22: Greenhouse, Linda. "Right-To-Die Case Gets First Hearing in Supreme Court. The New York Times. The New York Times, 07 Dec. 1989. Web. 23 Jan. 2014. .] [23: Nancy Cruzan. Sisters of Charity of Leavenworth Health System. Internet Archive Wayback Machine, 18 Nov. 2005. Web. 24 Dec. 2013. .]

Both the Cruzan and Quinlan cases greatly influenced the widespread practice of judicious neglect,[footnoteRef:24] or, passive euthanasia, wherein doctors agree to the requests of relatives of suffering, terminally ill patients and dont take great measures to preserve their lives. Additionally, the Cruzan case directly increased the interest in living wills and other such advance medical directives that allow individuals to describe beforehand what sort of treatment they would want, and should they be unable to make such decisions, who would do so. These changes reflect modern societys slow re-adaption to the historical practice of euthanasia. [24: Daley, Steve. "True Quinlan Legacy Just A Quiet Story."Chicago Tribune. Chicago Tribune, 14 June 1985. Web. 16 Mar. 2014. .]

The legalization of the termination of life-sustaining treatment or equipment essentially passive euthanasia caused discord, as it raised the question of whether directly causing the death of a suffering patient active euthanasia is substantially different from an ethical standpoint. According to Leslie Burkholder, a Department of Philosophy instructor at the University of British Columbia in Vancouver, Canada, no such ethical difference exists.[footnoteRef:25] In an article written for the Journal of Applied Philosophy, Burkholder cited two examples, Nancy B.[footnoteRef:26] and Nancy F., both of whose stories are based on real Canadian cases. Both Nancy B. and Nancy F. were afflicted with a muscle-wasting disease that destroyed their lungs. Nancy B. was attached to a medical ventilator, and will die of suffocation without it. Nancy F. will soon require the same medical ventilator, but for now, her original lungs are functioning, although poorly. Neither have any prospect of recovery and their conditions will only worsen, leading eventually to slow and painful deaths. Nancy B. wishes to terminate her life by turning off her mechanical ventilator and dying naturally, while Nancy F. wishes to be administered a lethal dose of morphine and die a peaceful death. Neither of them is capable of carrying out these actions by themselves, and they must seek the assistance of another, likely a certified medical professional. Within the eyes of the law, the one who terminates the life of Nancy F. will be considered a murderer, while the end of Nancy B.s life will simply be seen as expiration from existing natural causes.[footnoteRef:27] The two actions should not be considered so differently under the eyes of the law, since the difference is solely in the process of their death, not in the morality or intentions of the physician who assists in their passing. It is as with passive and active euthanasia merely factual, not ethical. [25: Harris, Nancy. No Ethical Difference Exists Between Active and Passive Euthanasia. The Ethics of Euthanasia. San Diego: Thomson/Gale, 2005. 9-12. Print.] [26: Nancy B. v. Htel-Dieu De Qubec Et Al. 86 D.L.R. (4th) 385. 31 A.C.W.S. (3d) 160. 69 C.C.C. (3d) 450. Superior Court of Quebec. 6 Jan. 1992. Uottawa.ca. Uottawa, n.d. Web. 20 Jan. 2014. .] [27: McFadden 1.]

Perhaps the most famous case of active euthanasia is the 1998 case of Thomas Youk. Dr. Jack Kevorkian, a physician and well-known apologist for the euthanasia movement in the late twentieth century, administered a lethal injection to the amyotrophic lateral sclerosis (ALS, popularly known as Lou Gehrigs Disease) patient, after being asked to do so multiple times by Thomass brother. His videotaped footage of the event was later featured during his 60 Minutes interview, wherein Thomass wife, Melody, commented that she was so grateful that someone would relieve him of his suffering.[footnoteRef:28] She stated that she did not consider it murder, but rather humane and the way things should be.[footnoteRef:29] Despite being asked to wait an extra week to consider his options, Thomas decided the next night that he wanted the injection that moment; he just couldnt stand it any longer, despite being a fighter,[footnoteRef:30] as his family had described him. Dr. Kevorkians concluding statement in the interview was that euthanasia is part of the American freedoms. If you dont have liberty and self-determination, youve got nothing this is the ultimate self-determination; to determine how and when youre going to die, and when youre suffering.[footnoteRef:31] [28: Dr. Jack Kevorkians 60 Minutes Interview. Interview by Overtime Staff. CBS News. CBS Interactive, 03 June 2011. Web. 05 Nov. 2013.] [29: Ibid.] [30: Ibid.] [31: Ibid.]

In Vacco v. Quill, Dennis C. Quill argued a similar point in the U.S. Supreme Court during 1997. He asserted that the equal protection clause of the Fourteenth Amendment of the U.S. Constitution was violated because terminally ill patients who are on life support have the right to medical assistance in shortening their own lifespan, while those who are not on life support are denied that right. Additionally, he argued that the due process clause of the Fourteenth Amendment is violated as well, as it ought to protect the right of a terminally ill, mentally competent patient to make the choice to seek the assistance of a doctor in committing suicide. Quill then argued that suicide and euthanasia are the same from an ethical perspective, meaning that, as suicide is legal, euthanasia should be legalized.However, euthanasia is not only a controversial debate within the courts, but also within religion. After the fall of Rome and emergence of Christianity, euthanasia had fallen from popular practice. Today, religious groups, especially Christian sects, still provide some of the greatest opposition against euthanasia. Euthanasia and suicide are often described as a sin in the Bible. The Fifth Commandment might also be perceived to encompass suicide and euthanasia. However, suicide is never specifically prohibited in either the Old or New Testaments. In fact, there are several suicides throughout the Bible (Samson[footnoteRef:32], Saul[footnoteRef:33], Abimelek[footnoteRef:34], and Judas[footnoteRef:35]) and none of them have ever been criticized. One of those four suicides can be interpreted as active euthanasia. Abimelek had said to his armor-bearer, Draw your sword and kill me And the young man thrust him through, and he died.[footnoteRef:36] The sole difference between his death and Sauls death was that Sauls armor bearer refused to assist him, forcing Saul to die by his own hand,[footnoteRef:37] while in Abimeleks case, his armor bearer had consented. However, the two cases are not viewed differently by Christian teachings. [32: Judges 16:23-31. The Holy Bible, Todays New International Version. N.p.: Zondervan, 2005. Print.] [33: 1 Samuel 31. The Holy Bible, Todays New International Version. N.p.: Zondervan, 2005. Print.] [34: Judges 9:52-55. The Holy Bible, Todays New International Version. N.p.: Zondervan, 2005. Print.] [35: Matthew 27:3-8. The Holy Bible, Todays New International Version. N.p.: Zondervan, 2005. Print.] [36: Judges 9:54. The Holy Bible, Todays New International Version. N.p.: Zondervan, 2005. Print.] [37: 1 Samuel 31:4. The Holy Bible, Todays New International Version. N.p.: Zondervan, 2005. Print.]

Throughout history, the cessation of physical suffering and alleviation of emotional strains upon the friends and family of the patient have been two key realities of the argument that euthanasia is a fundamental right that should be granted to terminally ill patients who are suffering, and no longer wish to live. Lord Dawson once described euthanasia as a mission of mercy[footnoteRef:38] a simple, yet thorough definition. Euthanasia is truly nothing more than a mission to provide mercy to those who are suffering, and the family of the suffering patient. Although active euthanasia is still debated today, that may change four[footnoteRef:39], perhaps soon five[footnoteRef:40], U.S. states, and two European countries[footnoteRef:41] have legalized it. In his concluding statement to a pro-euthanasia speech delivered in the House of Lords, Lord Dawson explained that one should make the act of dying more gentle and more peaceful even if it does involve curtailment of the length of life. That has been increasingly the custom. This may be taken as something accepted.[footnoteRef:42] [38: Lelyveld 1.] [39: ProCon.org. "Historical Timeline - Euthanasia." ProCon.org Headlines. ProCon.org, 23 July 2014. Web. 8 Mar. 2014. .] [40: Eckholm, Erik. "New Mexico Judge Affirms Right to Aid in Dying." The New York Times. The New York Times, 13 Jan. 2014. Web. 08 Mar. 2014. .] [41: ProCon.org 1.] [42: Lelyveld 1.]

Works Cited Primary Sources"ACLU Amicus Brief in Vacco v. Quill." American Civil Liberties Union. ACLU Foundation, 10 Dec. 1996. Web. 14 Dec. 2013. . ACLU's Amicus Brief in the Vacco v. Quill case thoroughly describes Vacco's argument against outlawing euthanasia, concentrating mainly on how the act of outlawing it violates the Fourteenth Amendment of the U.S. Constitution, and may cause greater suffering. The Vacco v. Quill case was an important part of the euthanasia movement that promoted public interest in the issue. This source was beneficial to me because it allowed me to have general idea of what occurred in the case before reading the actual Vacco v. Quill Supreme Court Case. Also, unlike the court case itself, the amicus brief was much easier to understand and follow, allowing an even clearer understanding of the case.Cial. "Right-to-Die Case Sent To the Supreme Court." The New York Times. The New York Times, 14 Mar. 1989. Web. 23 Jan. 2014. . Cial's article briefly describes Nancy Cruzan's situation and announces that the Cruzans are going to take their case to the U.S. Supreme Court in their attempt to allow her daughter to cease medically-assisted hydration and nutrition. The Cruzan case was a vital part in the euthanasia movement that gripped the American public's interest and promoted living wills and other such advance medical directives. This particular article was useful to me because it provided an insight to the public feelings and reactions to the Cruzan case before the Supreme Courts verdict, and allowed me to compare them to the reactions and feelings after the Court made and publicized their decision, allowing me to make a better analysis of how the Cruzan case specifically changed the public view on euthanasia.Cruzan v. Director. U.S. Supreme Court. 25 June 1990. Legal Information Institute. Cornell University Law School, n.d. Web. 24 Dec. 2013. . Within this case, Nancy Cruzan's parents argue that their daughter ought to be allowed to be taken off life support, after having suffered irreversible brain damage and falling into a persistent vegetative state, with no chance of recovery. The Cruzan case was a vital milestone in the euthanasia debate because it not only reinforced the court's rulings in the Quinlan case, but it also promoted interest in living wills and other such advance medical directives. This case was a particular interest to me in my research because it originated from Missouri, allowing me to discuss an event that occurred, at least in the beginning, in my home state. It, paired with the Quinlan case, helped to reform the public view on euthanasia. This source in particular was helpful because it provided a very complete outlook on the Cruzan case and assisted in my analysis of it."Dr. Jack Kevorkian's "60 Minutes" Interview." Interview by Overtime Staff. CBSNews. CBS Interactive, 03 June 2011. Web. 05 Nov. 2013. . The "60 Minutes" Interview showed the video footage that Dr. Kevorkian took while terminating the life of Thomas Youk, and provided the reactions of both Thomas Youk's family and a medical ethics professional, showing both the pro side of the argument, as well as the con's side. This was likely Kevorkian's most popular case of euthanasia, as it was the only instance of active euthanasia. He described it as a way of raising the limit so that the decision would finally be decided, saying that either they go or I go, they referring to the prosecutors. This source was particularly beneficial to my research because it not only showed the original video footage, but it also provided interviews with the family of Thomas Youk, which served as a way of showing how the families of other euthanized patients might have felt.Eckholm, Erik. "New Mexico Judge Affirms Right to Aid in Dying." The New York Times. The New York Times, 13 Jan. 2014. Web. 08 Mar. 2014. . Eckholm's article describes a New Mexico judge's court ruling that affirms a right to physician-assisted suicide, as well as the case surrounding it. This is the U.S.'s most recent progression in the legalization of euthanasia throughout the nation, followed by Vermont's legalization of the practice last year. If New Mexico continues down this path, it will become the fifth state to allow active euthanasia. This article was helpful for proving how euthanasia is still an ongoing, very current debate, even though it dates very far back into history. Greenhouse, Linda. "Does Right to Privacy Include Right to Die? Court to Decide." The New York Times. The New York Times, 25 July 1989. Web. 23 Jan. 2014. . Greenhouse's article discusses how the "right to privacy" protected by the U.S. Constitution may or may not encompass the "right to die," and how that was used within the Cruzan's argument as they fought for their daughter to be taken off of her medically-assisted nutrition and hydration. This argument connected the Cruzan and Quinlan case even further, as Paul W. Armstrong, the Quinlans lawyer, had used the right to privacy in his argument for Karen Ann Quinlans right to die. The article also included several statements from the Cruzan's themselves regarding their opinions. ---. "Right-To-Die Case Gets First Hearing in Supreme Court." The New York Times. The New York Times, 07 Dec. 1989. Web. 23 Jan. 2014. . Greenhouse's article briefly discusses the previous occurrences in the Cruzan case and reports that the family of Nancy Cruzan are about to have their first hearing in the U.S. Supreme Court as they appeal for the Supreme Court to overturn the ruling of the Missouri Courts. The Cruzan case was a vital milestone in the euthanasia movement because it promoted public interest in advance medical directives and reinforced the court's ruling in the Quinlan case. "Interview with Jack Kevorkian." Interview by HBO. HBO: You Don't Know Jack: Interview: Jack Kevorkian. HBO, n.d. Web. 05 Nov. 2013. . HBO's interview with Dr. Jack Kevorkian shows the doctor's thoughts and argument on the matter of euthanasia, as well as his counter-arguments to those made by the opposing side. Here, he also references Lord Dawson and his termination of King George V's life. Dr. Kevorkian also speaks of the people who came to see him, but were ultimately convinced (by the doctor himself) to not accept his treatment, and states that he had helped them too, as they felt better afterwards, knowing that there was someone there who could help them pass on if the suffering ever came to be too much. Johnson, Constance. Belgium: Euthanasia Opinion May Be Extended to Children. Global Legal Monitor. Library of Congress, 17 Dec. 2013. Web. 14 May 2014. .This article discussed Belgium, one of the two European countries to legalize active euthanasia. It describes how the country now wishes to expand the right to euthanasia to encompass children as well. If this law passes, Belgium will become the first country to legalize euthanasia without an age limit. This helped to not only show that euthanasia is not an isolated American problem, but a hot-button issue debated around the globe, but also that the interest and acceptance of the practice is expanding.Johnson, Kirk. "Ruling by Montana Supreme Court Bolsters Physician-Assisted Suicide." The New York Times. The New York Times, 31 Dec. 2009. Web. 08 Mar. 2014. . Johnson's article describes the Montana Supreme Court's decision to allow physician-assisted suicide. It was first proposed in 2008 when a Montana district judge, Dorothy McCarther, ruled in Baxter v. State of Montana that Montana residents had a right to physician-assisted suicide. The Montana Supreme Court affirmed her decision a year later, and Montana officially became the third U.S. state to legalize the practice. This article helped to show me that, although euthanasia was a historical practice that dated as far back as the time of the ancient Greeks and Romans, it still exists as a controversial issue today.Ledbetter, Les. "California Grants Terminally Ill Right to Put an End to Treatment." The New York Times. The New York Times, 02 Oct. 1976. Web. 08 Mar. 2014. Ledbetter's article describes Governor Edmund G. Brown Jr.'s signing of the California Natural Death Act into the law. With this event, California became the first state in the United States to allow passive euthanasia, likely motivated by the Quinlan case. In the next year, California inspires seven other states to follow its footsteps. It is a stepping stone in the legalization of euthanasia in the U.S. This article helped to show me that, although euthanasia was a historical practice that dated as far back as the time of the ancient Greeks and Romans, it still exists as a controversial debate today.Malcolm, Andrew H. "Nancy Cruzan: End to Long Goodbye." The New York Times. The New York Times, 29 Dec. 1990. Web. 23 Jan. 2014. . Malcolm's article allowed a view into the opinions and statements of Nancy Cruzan's parents after they won their case and Nancy was allowed to die. The Cruzan case was a vital part of the euthanasia movement because it promoted the use of living wills. It also supported the judicial neglect and passive euthanasia that was argued during the Karen Ann Quinlan case. It described Nancys death, and her parents reactions and feelings afterwards. Their opinions served as an example to how the friends and family of euthanized patients may feel.Nancy B. v. Htel-Dieu De Qubec Et Al. 86 D.L.R. (4th) 385. 31 A.C.W.S. (3d) 160. 69 C.C.C. (3d) 450. Superior Court of Quebec. 6 Jan. 1992. Uottawa.ca. Uottawa, n.d. Web. 20 Jan. 2014. . Similar to the Quinlan and Cruzan cases, the Nancy B. case deals with passive euthanasia and permitting a terminally ill patient to die. However, in this case, Nancy B. was not in a persistent vegetative state, despite that she had no prospect of recovery. This case provided a bit of information regarding the views of euthanasia in other countries (Canada), as well the results of cases not involving a comatose petitioner. This case, paired with the case of Nancy F., was the center of Leslie Burkholders argument that passive and active euthanasia are not ethically or morally different form each other. This case helped me to realize that euthanasia is not a controversial debate in just the United States it also exists within other countries, including Canada and England."Opinion 2.20 - Withholding or Withdrawing Life-Sustaining Medical Treatment." AMA-ASSN.org. American Medical Association, June 1984. Web. 08 Mar. 2014. < http://www.ama-assn.org//ama/pub/physician-resources/medical-ethics/code-medical-ethics/opinion220.page>. The American Medical Association, a long-standing opposer of euthanasia, published two articles that support withholding and/or withdrawing life-prolonging medical treatment in certain circumstances. This is the beginning of the medical acceptance of euthanasia in American. It was the first time that the American medical society had accepted passive euthanasia as a legitimate method of ending one's life, and this article helped to express that."Potter and Euthanasia." TIME Magazine. TIME Magazine, 31 Jan. 1938. Web. 8 Mar. 2014. . This TIME article provided information about Charles Francis Potter's creation of the National Society for the Legalization of Euthanasia (NSLE) in January of 1938. It was helpful in learning about Potter's organization because he was well-funded and well-backed, and it seemed like he truly had a good chance in legalizing euthanasia. He created NSLE just before the changing point of the American public opinion of euthanasia (the turning point occurred due to the revealing of the Nazis Action T-4). Robbins, William. "Another State Joins Right-to-Die Issue." The New York Times. The New York Times, 25 Nov. 1987. Web. 23 Jan. 2014. . Robbins's article discussed in detail the recent (at that time) occurrences in the Cruzan's fight to remove their daughter's feeding tubes. It also contains an interview of the parents with their opinion and views. The Cruzan's case was a pinnacle in the euthanasia movement because it directly caused the passing of the Patient Self-Determination Act, and greatly increased the public interest in living wills. ---. "Missouri's High Court Bars Life Support Removal." The New York Times. The New York Times, 17 Nov. 1988. Web. 23 Jan. 2014. . Robbins's article announces the results of the Cruzan v. Director case (in the Missouri Supreme Court), wherein the Cruzans lost. It also includes the reactions of the Cruzans after their request was denied. Shortly after their request was denied, the Cruzans had turned to the U.S. Supreme Court and re-filed their request there. That case was a milestone in euthanasia in the United States because it lead to the passing of the Patient Self-Determination Act. Vacco, Dennis C. "High Court Rejects Constitutional Right To Doctor-Assisted Suicide." American Civil Liberties Union. ACLU Foundation, 26 June 1997. Web. 03 Dec. 2013. . Vacco's article provides the pro-euthanasia argument of himself, and ACLU's National Legal Director, and their thoughts after the High Court rejected both of Vacco's arguments that the U.S. Constitution protects the right of terminally ill patients to be allowed physician-assisted suicide. He argues against the anti-euthanasia viewpoint of Chief Justice William H. Requist, who had rejected Vacco's petition. This article was helpful because, it not only provided a brief, concise, and easily understandable summary of the Vacco v. Quill case itself, but it also expressed the opinions of both the pro- and con- sides, helping me to see both sides of the argument.Vacco v. Quill. U.S. Supreme Court. 26 June 1997. Legal Information Institute. Cornell University Law School, n.d. Web. 24 Dec. 2013. . Within this case, Vacco thoroughly outlines his argument that terminally ill patients ought to be allowed the choice of physician-assisted suicide. He argues that this is a right protected by the Fourteenth Amendment of the U.S. Constitution. He also argued that outlawing euthanasia may lead to many patients experiencing greater suffering. This case was one of the major milestones in the euthanasia movement in America. Washington v. Glucksberg. U.S. Supreme Court. 26 June 1997. Legal Information Institute. Cornell University Law School, n.d. Web. 8 Mar. 2014. . Washington v. Glucksberg concerns four physicians who often tend to suffering and terminally ill patients. The four physicians filed a complaint and went to court, asking for a right to die that allowed physician-assisted suicide. Their case eventually went to the U.S. Supreme Court, where it was held that Washington's prohibition of physician-assisted suicide did not violate the due processes clause of the 14th Amendment. The four physicians ultimately lost their case. This case was referenced to in the Vacco v. Quill case.Washington v. Glucksberg. U.S. Supreme Court. 26 June 1997. ProCon.org. ProCon.org, n.d. Web. 8 Mar. 2014. . This was Chief Justice Rehnquist's delivery of his opinion concerning Washington v. Glucksberg to the court. He hit several key points that are often used in the opposing side of euthanasia debate. One of the points that he made was that for most of American history, euthanasia and suicide have been outlawed; they had been made illegal during the time of the colonies. He stated that he disagreed with the petitioner's statement that Washington's prohibition of assisted suicide violated the due processes clause of the Fourteenth Amendment. Zeldin, Wendy. "China: Case of Assisted Suicide Stirs Euthanasia Debate."Global Legal Monitor. Library of Congress, 17 Aug. 2011. Web. 14 May 2014.