Americans United for Life

Americans United for Life protects and defends human life from conception to natural death through vigorous legislative, judicial, and educational leadership.

Suicide by Physician

New York Gov. Andrew Cuomo advocates suicide by physician



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Tom Shakely, Chief Engagement Officer at Americans United for Life, responds to Gov. Andrew Cuomo’s recent advocacy of suicide by physician for New Yorkers.

Tom Shakely appears with Kristen Hanson, Community Relations Advocate for the Patients’ Rights Action Fund as well as Dennis Vacco, former New York State Attorney General. Dennis Vacco successfully argued the landmark 1997 U.S. Supreme Court case Vacco v. Quill, wherein the Supreme Court ruled 9-0 that no constitutional right to physician-assisted suicide exists.

 “The American Medical Association has been clear on this,” Shakely said. “Their Code of Medical Ethics opposes physician-assisted suicide. It says it’s ‘fundamentally incompatible with the physician’s role as healer.’ So this isn’t a medical issue, the root is suicide. It’s not about assistance. It’s not about nice words. It’s politics interfering with medicine, at the end of the day.”

Importantly, Gov. Andrew Cuomo’s father, Gov. Mario Cuomo, established the New York State Department of Health’s “Task Force on Life and the Law,” which in 1994 concluded the following:

Assisted suicide and euthanasia would carry us into new terrain. American society has never sanctioned assisted suicide or mercy killing. We believe that the practices would be profoundly dangerous for large segments of the population, especially in light of the widespread failure of American medicine to treat pain adequately or to diagnose and treat depression in many cases. The risks would extend to all individuals who are ill. They would be most severe for those whose autonomy and well-being are already compromised by poverty, lack of access to good medical care, or membership in a stigmatized social group. The risks of legalizing assisted suicide and euthanasia for these individuals, in a health care system and society that cannot effectively protect against the impact of inadequate resources and ingrained social disadvantage, are likely to be extraordinary.

… The media’s coverage of individual cases as a way of presenting the issues to the public also blurs the difference between a private act and public policy; between what individuals might find desirable or feasible in a particular case and what would actually occur in doctors’ offices, clinics, and hospitals, if assisted suicide and euthanasia became a standard part of medical practice. Public opinion polls, focusing on whether individuals think they might want these options for themselves one day, also offer little insight about what it would mean for society to make assisted suicide or direct killing practices sanctioned and regulated by the state or supervised by the medical profession itself.

Maryland’s ‘End of Life Options Act,’ intended to permit suicide by physician, is defeated



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Americans United for Life is grateful to Maryland leaders and advocates for life for the recent defeat of the so-called “End of Life Options Act,” a bill which would have permitted state-endorsed suicide by physician in Maryland, threatened the lives of vulnerable persons, and corroded the rights of conscience of medical providers. Unfortunately, the “End of Life Options Act” is likely to return in the next legislative session, as its defeat occurred only due to the Maryland Senate’s 23-23 deadlock vote. Americans United for Life stands ready to advocate for life if and when Maryland legislators consider similar legislation.

Americans United for life spoke forcefully on the realities of Maryland’s “End of Life Options Act”, revealing the legislation for what it was:

“It would be a tragedy for Maryland to embrace suicide by physician, as HB 399 would do,” said Catherine Glenn Foster, President & CEO of Americans United for Life. “It’s a straightforward reality that any law that empowers one person to take the life of another would be unjust, and that reality doesn’t change simply because one happens to be a physician. To permit the intentional and premature ending of human life would open Maryland up to all variety of injustice and abuse, and should be avoided by any legislature concerned with an equitable and justice-oriented society.”

Americans United for Life also provided critical testimony against Maryland’s “End of Life Options Act,” underscoring that suicide is never an appropriate or rational act:

Currently, the overwhelming majority of states—at least 39 states—affirmatively prohibit assisted suicide and impose criminal penalties on anyone who helps another person end his or her life. And since Oregon first legalized the practice in 1996, “about 200 assisted-suicide bills have failed in more than half the states.” In Washington v. Glucksberg, the United States Supreme Court summed up the consensus of the states: “In almost every State—indeed, in almost every western democracy—it is a crime to assist a suicide. The States’ assisted-suicide bans are not innovations. Rather, they are longstanding expressions of the States’ commitment to the protection and preservation of all human life.”

This longstanding consensus among the vast majority of states is unsurprising when one considers, as the Court did, that “opposition to and condemnation of suicide—and, therefore, of assisting suicide—are consistent and enduring themes of our philosophical, legal and cultural heritages.” Indeed, over twenty years ago, the Court in Glucksberg held there is no fundamental right to assisted suicide in the U.S. Constitution, and instead found that there exists for the states “an ‘unqualified interest in the preservation of human life[,]’ … in preventing suicide, and in studying, identifying, and treating its causes.” …

[T]he American Medical Association (AMA) does not support physician-assisted suicide, even for individuals facing the end of their life. The AMA states that “permitting physicians to engage in assisted suicide would ultimately cause more harm than good. Physician-assisted suicide is fundamentally incompatible with the physician’s role as healer, would be difficult or impossible to control, and would pose serious societal risks.” In fact, the AMA emphasizes that physicians must “aggressively respond to the needs of the patients” and “respect patient autonomy [and] provide appropriate comfort care and adequate pain control.”

New Jersey set to permit suicide by physician



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Despite the New Jersey legislature’s approval of suicide by physician, and the stated intention of Governor Phil Murphy to sign suicide by physician into New Jersey law, Americans United for Life underscores the good news that more states have acted to affirmatively protect their citizens from suicide by physician over the past 20 years than have implemented state-endorsed suicide. Americans United for Life encourages leaders in other states to expand life-affirming choice for persons facing difficult medical situations, particularly those living in poverty, members of the disability community and elder adults.

“It’s a tragedy that New Jersey politicians have passed the so-called ‘Medical Aid in Dying for the Terminally Ill Act’, because while this bill sounds innocuous, its name masks its true purpose,” states Catherine Glenn Foster, President & CEO of Americans United for Life, “which is the legalization of a new form of suicide for persons who might merely be facing the prospect, rather than the certainty, of a terminal situation.”

“We know from national and international experience that these bills always expand in scope,” continues Foster, “which means that what today might seem to some to be reasonable and limited will tomorrow become permissive of a variety of forms of intentional death for persons of all ages and conditions. Once suicide by physician is legalized in any form, the deadly logic behind state-endorsed intentional killing always expands to the point that there are functionally no limits on what sort of self-inflicted violence one might carry out on oneself—or demand a physician or another carry out on their behalf.”

New Jersey is set to become only the seventh state in the nation to condone suicide by physician, sometimes called “physician assisted suicide” or “medical aid in dying”. Americans United for Life advocates comprehensive suicide prevention efforts in light of an apparently increasing sympathy for certain forms of suicide, and encourages persons considering suicide by physician to seek assistance through the National Suicide Prevention Lifeline and other national and local resources.

Americans United for Life continues to advocate for life-affirming law and policy, and for the rights of conscience for physicians, nurses, and medical personnel who do not consent to facilitating the suicides of vulnerable persons. As Ezekiel J. Emanuel underscores:

“Patients themselves say that the primary motive is not to escape physical pain but psychological distress; the main drivers are depression, hopelessness and fear of loss of autonomy and control. Dutch researchers [who] … followed 138 terminally ill cancer patients and found that depressed patients were four times more likely to request euthanasia or physician-assisted suicide. Nearly half of those who requested euthanasia were depressed.

“In this light, physician-assisted suicide looks less like a good death in the face of unremitting pain and more like plain old suicide. Typically, our response to suicidal feelings associated with depression and hopelessness is not to give people the means to end their lives but to offer them counseling and caring.”

We can work together to foster a culture that affirms all human life, and rejects violence and self-harm as unethical and illegitimate responses to the challenge of human dignity and solidarity.

Testimony on New Jersey S.B. 1072, involving suicide by physician



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Written Testimony of Catherine Glenn Foster, Esq.

On S.B. 1072

Submitted to the Committee on Health, Human Services, and Senior Citizens

February 7, 2019

Dear Chair Vitale and Members of the Committee:

            My name is Catherine Glenn Foster and I serve as President and CEO with Americans United for Life (AUL), the oldest and most active pro-life non-profit advocacy organization. Established in 1971, AUL has dedicated nearly 50 years to advocating for everyone to be welcomed in life and protected in law. In my practice, I specialize in life-related legislation and am testifying as an expert in constitutional law generally and in the constitutionality of end of life-related laws specifically. I have also written extensively on the end-of-life issue, most recently in The Human Life Review.[1] I appreciate the opportunity to provide written testimony against S.B. 1072, which would legalize physician-assisted suicide in New Jersey.

I have thoroughly reviewed S.B. 1072, and it is my opinion that S.B. 1072 goes against the prevailing consensus that states have a duty to protect life, places already vulnerable people groups at greater risk, and fails to protect the integrity and ethics of the medical profession.

The Majority of States Affirmatively Prohibit Physician-Assisted Suicide

Currently, over 40 states affirmatively prohibit assisted suicide and impose criminal penalties on anyone who helps another person end his or her life. In Washington v. Glucksberg, the United States Supreme Court summed up the consensus of the states: “In almost every State—indeed, in almost every western democracy—it is a crime to assist a suicide. The States’ assisted-suicide bans are not innovations. Rather, they are longstanding expressions of the States’ commitment to the protection and preservation of all human life.”[2]

This longstanding consensus among the vast majority of states is unsurprising when one considers, as the Court did, that “opposition to and condemnation of suicide—and, therefore, of assisting suicide—are consistent and enduring themes of our philosophical, legal and cultural heritages.”[3] Indeed, over twenty years ago, the Court in Glucksberg held there is no fundamental right to assisted suicide in the U.S. Constitution, and instead found that there exists for the states “an ‘unqualified interest in the preservation of human life[,]’ . . . in preventing suicide, and in studying, identifying, and treating its causes.”[4]

Only by rejecting S.B. 1072 can this Committee further New Jersey’s important state interest in preserving human life and advance the State’s duty to protect the lives of its citizens, especially the lives of the most vulnerable groups in society.

Physician-Assisted Suicide Places Already Vulnerable People Groups at Greater Risk

It is critical for New Jersey to protect potentially vulnerable groups—including the poor, the elderly, and disabled persons—from abuse, neglect, and coercion. When considering the risks posed by assisted suicide to all of us, especially these vulnerable people groups, the availability of assisted suicide can be considered neither a compassionate nor an appropriate solution for those who may suffer at the end of life. Many in the bioethics, legal, and medical fields have raised significant questions regarding the existence of abuses and failures in jurisdictions that have approved physician-assisted suicide, which includes a lack of reporting and accountability, coercion, and failure to assure the competency of the requesting patient.[5] Even the most vulnerable among, such as the poor, the elderly, the terminally ill, the disabled, and the depressed, are worthy of life and equal protection under the law, and state prohibitions on assisted suicide reflect and reinforce the well-supported policy “that the lives of the terminally ill, disabled and elderly people must be no less valued than the lives of the young and healthy.”[6]

Physician-Assisted Suicide Erodes the Integrity and Ethics of the Medical Profession

Prohibitions on physician-assisted suicide also protect the integrity and ethics of the medical profession, including its obligation to serve its patients as healers, as well as the principles articulated in the Hippocratic Oath to “keep the sick from harm and injustice” and to “refrain from giving anybody a deadly drug if asked for it, nor make a suggestion to this effect.”[7] Likewise, the American Medical Association (AMA) does not support physician-assisted suicide, even for individuals facing the end of their life. The AMA states that “permitting physicians to engage in assisted suicide would ultimately cause more harm than good. Physician-assisted suicide is fundamentally incompatible with the physician’s role as healer, would be difficult or impossible to control, and would pose serious societal risks.”[8] In fact, the AMA emphasizes that physicians must “aggressively respond to the needs of the patients” and “respect patient autonomy [and] provide appropriate comfort care and adequate pain control.”[9]

There is also a thin line between physician-assisted suicide and euthanasia where the “right to die” can quickly become the “duty to die.” As the New Jersey legislature noted, the “great majority of patients who requested medication” to end their life were in hospice care.[10] The prohibition of assisted suicide is the only reasonable means to protect against this foreseeable abuse.[11] Importantly, although the original stated intent in most jurisdictions with physician-assisted suicide laws is to provide “a last-resort option for a very small number of terminally ill people, some jurisdictions now extend the practice to newborns, children, and people with dementia. A terminal illness is no longer a prerequisite.”[12]

“Safeguards” Do Not Always Work

Despite the so-called “safeguards,” opening the door for physician-assisted suicide also opens the door to real abuse. For example, S.B. 1072 requires that there are two witnesses to the request for life-ending medication, but only one must be a disinterested party, at least in theory. There is no requirement that the second witness be completely disinterested, meaning an heir and her best friend would satisfy the two-witness requirement, easily circumventing the alleged safeguard designed to protect the patient from pressure, coercion, or abuse.

One need only look to the Netherlands and Belgium to see how this plays out. A report commissioned by the Dutch government demonstrated that more than half of assisted-suicide and euthanasia related deaths were involuntary in the year studied.[13] At least half of Dutch physicians actively suggest euthanasia to their patients.[14] Additionally, another study showed that out of 1,265 nurses questioned, 120 of them (almost 10 percent) reported that their last patient was involuntarily euthanized.[15] But only four percent of nurses involved in involuntary euthanasia reported that the patient had ever expressed his or her wishes about euthanasia. Most of the patients euthanized without consent were over 80 years old, reaffirming the fact that assisted suicide and euthanasia quickly lead to elder abuse.

In conclusion, New Jersey should reject physician-assisted suicide and continue to uphold its duty to protect the lives of all its citizens—especially vulnerable people groups such as the ill, elderly, and disabled—and maintain the integrity and ethics of the medical profession by rejecting S.B. 1072.

Sincerely,

Catherine Glenn Foster
President & CEO
Americans United for Life

[1] Catherine Glenn Foster, The Fatal Flaws of Assisted Suicide, 44 Human Life Rev. 51 (2018).

[2] 521 U.S. 702, 710 (1997).

[3] Id. at 711.

[4] Id. at 729–30.

[5] J. Pereira, Legalizing Euthanasia or Assisted Suicide: The Illusion of Safeguards and Controls, 18 Current Oncology e38 (2011) (finding that “laws and safeguards are regularly ignored and transgressed in all the jurisdictions and that transgressions are not prosecuted”); see also Wash. State Dep’t of Health, Washington State Death with Dignity Act Report (2018), https://www.doh.wa.gov/Portals/1/Documents/Pubs/422-109-DeathWithDignityAct2017.pdf (In 2017, 56% of patients who died after ingesting a lethal dose of medicine in Washington did so, at least in part, because they did not want to be a “burden” on family members, raising the concern that patients were pushed to suicide.).

[6] Glucksberg, 521 U.S. at 731–32.

[7] The Supreme Court has recognized the enduring value of the Hippocratic Oath: “[The Hippocratic Oath] represents the apex of the development of strict ethical concepts in medicine, and its influence endures to this day. . . . [W]ith the end of antiquity . . . [t]he Oath ‘became the nucleus of all medical ethics’ and ‘was applauded as the embodiment of truth’” Roe v. Wade, 410 U.S. 113, 131–32 (1973).

[8]AMA Code of Medical Ethics Op. 5.7 (Physician–AssistedSuicide), https://www.ama-assn.org/sites/default/files/media-browser/code-of-medical-ethics-chapter-5.pdf.

[9] Id.

[10] S.B. 1072, 218th Leg. (N.J. 2018).

[11] Glucksberg, 521 U.S. at 734–35; Vacco v. Quill, 521 U.S. 793, 808–09 (1997).

[12] See Pereira, supra note 4.

[13]See W.J. Smith, Forced Exit: The Slippery Slope from Assisted Suicide to Legalized Murder 118–19 (2003) (citing the Dutch government’s Remmelink Report documenting euthanasia results in the Netherlands).

[14] See id. at 119 (citing R. Fenigsen, Report of the Dutch Government Committee on Euthanasia, 7 Issues Law & Med. 239 (Nov. 1991); Special Report from the Netherlands, N.E.J.M. 1699-711 (1996)).

[15] E. Inghelbrecht et al., The Role of Nurses in Physician-Assisted Deaths in Belgium, Can. Med. Assn. J. (June 15, 2010).

Hope After Hawaii



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As advocates for the legalization of assisted suicide loudly celebrate victory in Hawaii, it would be very easy to become discouraged— but don’t. While Hawaii is certainly a setback that may have potentially fatal consequences for some of the vulnerable citizens of the Aloha State, the broader view of the fight against assisted suicide is one of hope.

Currently, there are 41 states that affirmatively prohibit physician-assisted suicide and impose criminal penalties on anyone who helps another person end his or her life. In 1997, Oregon became the first jurisdiction in the U.S. to establish a state-sanctioned system for physician-assisted suicide. Since then, six jurisdictions (Washington in 2008, Vermont in 2013, California and Colorado in 2016, D.C. in 2017, and Hawaii in 2018) have waded into the murky waters of legalized assisted suicide. During that same period, 10 jurisdictions (Kansas, Maryland, Michigan, Oklahoma, South Carolina, and Virginia in 1998, Georgia in 2012, Alabama and Ohio in 2017, and Utah in 2018) have taken action to prohibit this dangerous practice. Even more encouragingly, state lawmakers have rejected more than 200 attempts to institute assisted suicide regimes. In addition, the state supreme courts in Alaska, Florida, New Mexico, and New York have all refused to find a “right to die” by assisted suicide in their state constitutions.

This trend continues into the 2018 session as well. AUL has joined with a broad coalition of physicians, patients’ rights groups, disability advocates, pro-life groups, and elder care advocates to fight back against assisted suicide legislation in Alaska, Connecticut, Massachusetts, and Rhode Island. The legislatures of Connecticut and Massachusetts have both already rejected the bills in question, and we continue to work with our coalition allies to fight in Alaska and Rhode Island.

But perhaps the greatest hope lies in the integrity of the medical profession, who clearly take their oath to “do no harm” very seriously with regards to this issue. One year after legalizing assisted suicide, the District of Columbia has seen that physicians are unwilling to participate in killing the patients they are charged with healing. Reports show that fewer than 0.0002% of the District’s physicians are willing to participate in assisted suicide. Our hope at AUL is that the physicians of Hawaii will follow this example and refuse to participate in the taking of human life.

Testimony On S. 1225 Regarding Physician-Assisted Suicide



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 Testimony of Deanna Wallace, Esq., Staff Counsel, Americans United for Life,

                        On S. 1225 Regarding Physician-Assisted Suicide

September 26, 2017

Dear Chairs Lewis and Hogan, and Honorable Members:

I am Deanna Wallace, Staff Counsel with Americans United for Life.  I appreciate the opportunity to provide written testimony on S. 1225, regarding the legalization of physician-assisted suicide in Massachusetts. In my practice, I specialize in life-related legislation and am testifying as an expert in constitutional law generally and the constitutionality of end of life-related laws specifically.

I have thoroughly reviewed S. 1225, and it is my opinion that S. 1225 goes against the prevailing consensus that states have a duty to protect life, places already vulnerable people groups at greater risk, and fails to protect the integrity and ethics of the medical profession.

The Majority of States Affirmatively Prohibit Physician-Assisted Suicide

Currently, 42 states affirmatively prohibit assisted suicide, and impose criminal penalties on anyone who helps another person end his or her life. In Washington v. Glucksberg, the United States Supreme Court summed up the consensus, saying: “In almost every State—indeed, in almost every western democracy—it is a crime to assist a suicide.  The States’ assisted suicide bans are not innovations.  Rather they are longstanding expressions of the States’ commitment to the protection and preservation of all human life.”[1]

This longstanding consensus among the vast majority of states is unsurprising when one considers, as the Court did, that “opposition to and condemnation of suicide—and, therefore, of assisting suicide—are consistent and enduring themes of our philosophical, legal and cultural heritages.”[2]

Indeed, more than twenty years ago, the Supreme Court held that there is no fundamental right to assisted suicide in the U.S. Constitution, finding instead that there exists for the states “an unqualified interest in the preservation of human life… in preventing suicide, and in studying, identifying, and treating its causes.”[3]

Only by rejecting S. 1225 can this committee further Massachusetts’ important state interest in preserving human life, as well as its duty to protect the lives of her citizens, especially the lives of the most vulnerable groups in our society.

Physician-Assisted Suicide Places Already Vulnerable People Groups at Greater Risk

It is also critical to protect vulnerable groups—including the poor, the elderly, and disabled persons—from abuse, neglect, and coercion. When considering the risk posed to these vulnerable people groups, assisted suicide can be considered neither a “compassionate” nor an appropriate solution for those who may suffer at the end of life. Many in the bioethics, legal, and medical fields have raised significant questions regarding the existence of abuses and failures in jurisdictions that have approved physician-assisted suicide, including a lack of reporting and accountability, coercion, and failure to assure the competency of the requesting patient.[4]  America’s most vulnerable citizens, including the elderly, the terminally ill, the disabled, and the depressed, are worthy of life and equal protection under the law, and state prohibitions on assisted suicide reflect and reinforce the well-supported policy “that the lives of the terminally ill, disabled and elderly people must be no less valued than the lives of the young and healthy.”[5]

Physician-Assisted Suicide Erodes the Integrity and Ethics of the Medical Profession

Prohibitions on assisted suicide also protect the integrity and ethics of the medical profession, including its obligation to serve its patients as healers, as well as to the principles articulated in the Hippocratic Oath to “keep the sick from harm and injustice” and to “refrain from giving anybody a deadly drug if asked for it, nor make a suggestion to this effect.”  Likewise, the American Medical Association (AMA) does not support physician-assisted suicide, even for individuals facing the end of

life. The AMA states that “allowing physicians to participate in assisted suicide would cause more harm than good. Physician-assisted suicide is fundamentally incompatible with the physician’s role as healer, would be difficult or impossible to control, and would pose serious societal risks.”[6]

There is also a close link between physician-assisted suicide and euthanasia where a “right to die” easily becomes a “duty to die.”  The prohibition of assisted suicide is the only reasonable means to protect against these foreseeable abuses.[7] Importantly, although the original stated intent of most laws in jurisdictions that allow physician-assisted suicide is to provide “a last-resort option for a very small number of terminally ill people, some jurisdictions now extend the practice to newborns, children, and people with dementia. A terminal illness is no longer a prerequisite.”[8]

One only has to look to the Netherlands to see how this plays out in reality: a report commissioned by the Dutch government demonstrated that more than half of euthanasia and assisted-suicide-related deaths were involuntary in the year studied.[9] At least half of Dutch physicians actively suggest euthanasia to their patients.[10] Studies in 1997 and 2005 revealed that eight (8) percent of infants who died in the Netherlands were euthanized by doctors.[11]

The slippery slope is also manifest in Belgium. A study published in the Canadian Medical Association Journal[12] showed that out of 1,265 nurses questioned, 120 of them (almost 10 percent) reported that their last patient was involuntarily euthanized. Only four percent of nurses involved in involuntary euthanasia reported that the patient had ever expressed his or her wishes about euthanasia. Most of the patients euthanized without consent were over 80 years old, reaffirming the fact that assisted suicide and euthanasia quickly lead to elder abuse. The researchers acknowledged that nurses are likely reluctant to report illegal acts (here, euthanizing a patient without physician involvement)—thus, it is possible that the number of nurses killing their patients without physician involvement is much higher than revealed by the study. The researchers concluded that “[i]t seems the current law… and control system do not prevent nurses from administering life-ending drugs.” In other words, the “safeguards” purported by suicide advocates simply do not work.

Massachusetts should continue to uphold its duty to protect the lives of all its citizens, especially vulnerable people groups such as the ill, elderly, and disabled; and maintain the integrity and ethics of the medical profession by rejecting physician-assisted suicide, and rejecting S. 1225.

[1] Washington v. Glucksberg, 521 U.S. 702, 710 (1997).

[2] Id., at 711 and 723.

[3] Glucksberg, 521 U.S. at 729-30.

[4] J. Pereira, MBChB MSc, Legalizing Euthanasia or Assisted Suicide: The Illusion of Safeguards and Controls, 18(2) Current Oncology (2011) (finding that “laws and safeguards are regularly ignored and transgressed in all the jurisdictions and that transgressions are not prosecuted.”); see Washington State Department of Health 2010Death with Dignity Act Report, available at http://www.doh.wa.gov/portals/1/Documents/5400/DWDA2010.pdf  (last visited Feb. 27, 2017) (showing that in 2010, over one-fourth of patients who died after ingesting a lethal dose of medicine in Washington did so because, at least in part, they did not want to be a “burden” on family members, raising the concern that patients were pushed into suicide).

[5] Glucksberg, 521 U.S. at 731-32.

[6] American Medical Association, Code of Medical Ethics, Opinion 5.7 – Physician-Assisted Suicide, available at https://www.ama-assn.org/sites/default/files/media-browser/code-of-medical-ethics-chapter-5.pdf (last visited Feb. 27, 2017).

[7] Glucksberg, 521 U.S. at 734-35; Vacco v. Quill, 521 U.S. 793, 808-09 (1997).

[8] See Pereira, Legalizing Euthanasia or Assisted Suicide, 18(2) Current Oncology.

[9] See W.J. Smith, Forced Exit: The Slippery Slope from Assisted Suicide to Legalized Murder 118-19 (2003) (citing the Dutch government’s Remmelink Report).

[10] See id. at 119 (citing R. Fenigsen, Report of the Dutch Government Committee on Euthanasia, 7 Issues Law & Med. 239 (Nov. 1991); Special Report from the Netherlands, N.E.J.M. 1699-711 (1996).

[11] See id. at 129-30 (citing A. van der Heide et al., Medical End of life Decisions Made for Neonates and Infants in the Netherlands, 350 Lancet 251 (1997)); A.M. Vrakking et al., Medical End of life Decisions Made for Neonates and Infants in the Netherlands, 1995-2001, 365 Lancet 1329 (2005).

[12] E. Inghelbrecht et al., The role of nurses in physician-assisted deaths in Belgium, Can. Med. Assn. J. (June 15, 2010).