Illinois Death with Dignity Act: A Case for
Legislating Physician Assisted Suicide and Active Euthanasia
Illinois Death with Dignity Act: A Case for
Legislating Physician Assisted Suicide and Active
Euthanasia
family and not a concern of the State.
65
A. Illinois Do
es Not Have an Unqualified Interest i
n Extending the Lives of
its Residents
Illinois does not have an unqualified interest in preserving the lives of its
residents despite the holding of
Washington v. Glucksberg
, in which the
Supreme Court found that Washi
ngton did have this interest.
66
Washington
had a legitimate interest because the patients in
Washington
were asserting
an interest absent a state statute; however, if Illinois were to propose a
statute allowing for physician
-
assisted suicide and active euthanasia, then
that statute would qualify Illinois’ interests in its terminally ill patients.
67
A
state may have an interest in preserving the lives of citizens that are still
productive to society, but this interest must be weighed against the medical
conditions and the wishes of patients.
68
This balancing approach is better
because end of life care is costly
69
; an uninsured terminally
ill patient who
wishes to die may end up needlessly costing the state thousands of dollars
in order to prolong the patient’s life for a few more days or weeks.
70
Further, if a patient requests medication to end his life and Illinois law
continues to forbid it, then it appears that Illinois is mandating the suffering
of terminally ill patient
Vol. 23
Annals of Health Law
14
This article will argue that the Illinois legislature should propose a Death
with Dignity
Act modeled after Oregon’s Death with Dignity Act
(DWDA)
6
; however, Illinois should go a step further and also legalize
active euthanasia. First, this article will define the key terms needed to have
an informed conversation about this issue. The article w
ill differentiate
between such terms as active and passive euthanasia, as well as, unassisted
and assisted euthanasia. The second part of this article will explain what the
Oregon DWDA entails.
7
It will explain what procedural safeguards the
Oregon DWDA ha
s in place to ensure that its patients are not being coerced
or unduly influenced into making a decision to end their life. Finally, this
article will argue that Illinois should model legislation after Oregon’s
DWDA, and it should also legislate active eut
hanasia. It will support this
argument by showing that Illinois does not have an unqualified interest in
extending the lives of its residents
8
and that it is more humane to let a
terminally
-
ill patient die on his own terms rather than spend his last
moment
s of life needlessly suffering.
9
II.
D
EFINING THE
T
ERMS
In order to have a constructive discussion about the morality of
euthanasia and physician
-
assisted suicide, one should possess a working
knowledge of the key terms. Physician
-
assisted suicide is when
a doctor
facilitates a patient in their request to commit suicide by giving them either
the drugs necessary or the medical knowledge necessary to commit the
act.
10
Euthanasia is similar, but distinct; it is the act of causing, or speeding
assistance in exercising their right to die, their wishes should be respected.
”
).
6
.
O
R
.
R
EV
.
STAT.
§§ 127.800
-
97 (2013).
7
.
See infra
Part III.
8
.
See infra
Part IV.A.
9
.
See infra
Part IV.B.
10
.
See
B
LACK
’
S
L
AW
D
ICTIONARY
1475 (8th ed. 2004) (
“
The intentional act of
providing a person with medical means or the medical knowledge to commit suicide.
”
)
[hereinafter
B
LACK
’
S
].
15
Illinois Death with Dignity
Act
2014
up, the death of a
patient who suffers from either a terminal illness or an
especially incurable painful illness in order to alleviate the patient’s
suffering.
11
Voluntary active euthanasia is where a competent person makes
a decision or a request to be assisted in dying.
12
N
onvoluntary active
euthanasia occurs when an incompetent and mentally incapable person is
given medications or other interventions that cause death.
13
Involuntary
active euthanasia occurs when a competent person is put to death without
making a request to d
ie or without consent.
14
Passive euthanasia occurs
when a terminally ill person is allowed to die by either withholding or
withdrawing life
-
sustaining support.
15
A.
Active v
ersus Passive Euthanasia
On the surface, the distinction between active and passive euth
anasia
seems to be rather simple. Active euthanasia requires a person to take
affirmative measures, such as administering a lethal injection, whereas
passive euthanasia occurs when a person refuses to prevent an individual’s
11
.
See Id.
at 59
4 (
“
The act or practice of causing or hastening the death of a person
who suffers from an incurable or terminal disease or condition, esp. a painful one, for
reasons of mercy.
”
). Euthanasia is sometimes regarded by the law as second
-
degree murder,
manslaug
hter, or criminally negligent homicide.
Id.
In 2001, the Netherlands became the
first nation to legalize euthanasia.
Id.
12
.
R
OBERT
Y
OUNG
,
M
EDICALLY
A
SSISTED
D
EATH
2 (2007);
see also
K
EVIN
Y
UILL
,
A
SSISTED
S
UICIDE
:
T
HE
L
IBERAL
,
H
UMANIST
C
ASE
A
GAINST
L
EGALIZATION
11 (2013)
(defining voluntary euthanasia as ending another person
’
s life at his or her own
“
explicit
request
”
);
see, e.g.
,
Lawrence M. Hinman,
An Introduction to the Moral Issues
,
in
Contem
porary Moral Issues: Diversity and Consensus 102, 103 (Lawrence M. Hinman ed.,
3rd ed. 2006).
13
.
See
Y
UILL
,
supra
note
12
, at 11 (defining nonvoluntary euthanasia as ending an
incompetent and mentally incapable person
’
s life without
“
explicitly requesting it
”
);
see,
e.g.
,
Hinman,
supra
note
12
, at 103
-
104.
14
.
See
Y
UILL
,
supra
note
12
, at 11 (defining involuntary euthanasia as ending
competent person
’
s life without an
“
explicit request
”
or without
“
full informed consent
”
);
see, e.g.
,
Hinman,
supra
note
12
, at 104. Involuntary active euthanasia is essentially murder
because a person that wants to live is intentionally killed.
See
Young,
supra
note
12
, at 2
(
“
[N]o matter how honourable the perpetrator
’
s motive is in bringing about such death, it
constitutes homicide.
”
).
15
.
B
LACK
’
S
at 594. A good example of litigation regarding passive euthanasia is the
case of Karen Ann Quinlan in
In re Quinlan
348 A.2d 801,
modified and remanded
, 355
A.2d 647, the parents of Karen Ann Quinlan were allowed to remove artificial respiration,
allowin
g her to die from her illness.
Y
OUNG
,
supra
note
12
, at 6.
Vol. 23
Annals of Health Law
16
death.
16
In a hospital setting,
the most common form of passive euthanasia
is a Do Not Resuscitate (DNR) order.
17
The distinction between active and passive euthanasia is particularly
crucial in the field of medical ethics.
18
The crucial distinction between
active and passive euthanasia li
es in a doctor’s act
19
or omission
20
because
some find it acceptable to withhold life
-
sustaining treatment and allow a
patient to die, but unacceptable to take active measures to kill a patient.
21
The ordinary assessment of ethicists is that active euthanasia
is more
morally questionable than passive euthanasia because active euthanasia
requires taking an affirmative action to bring about the death of another
person.
22
However, this distinction might not be black and white, because
passive euthanasia does in fa
ct require an affirmative action to turn off life
-
sustaining equipment or an active choice to not administer drugs that would
prolong a patient’s life.
23
If a doctor switches off a patient’s respirator and
the patient dies as a result of the doctor turning
off the respirator, it is true
that the doctor is the immediate cause of the patient’s death.
24
Thus,
16
.
Hinman,
supra
note
12
, at 102.
17
.
Id.
18
.
James Rachels,
Active and Passive Euth
anasia
, 292
N
EW
E
NG
.
J.
M
ED
.
78 (1975),
available
at
http://www.qcc.cuny.edu/socialSciences/ppecorino/DeathandDying_TEXT/
Active%20and%20Passive%20Euthanasia.pdf
.
19
.
An act is
“
something done or
performed.
”
See
B
LACK
’
S
at 26.
20
.
An omission is
“
a failure to do something.
”
See id.
at 1121.
21
.
See
Rachels,
supra
note
18
. The distinction between active and passive euthanasia is
important because in some cases it is permissible to withhold life
-
sustaining treatment, but it
is never permissi
ble for a doctor to take active measures designed to kill a patient.
Id. See
also Active and Passive Euthanasia
,
BBC,
http://www.bbc.co.uk/ethics/euthanasia/
overview/activepassive_1.shtml
(last visited Feb. 24, 2014). Some medical professionals
agree with
this distinction because it allows them to provide for a patient who prefers death
to life
-
sustaining treatment while allowing them to avoid the ethical and legal problems they
would face if they were to actively kill a patient that wished to die.
Id.
(
“
T
hey think it allows
them to provide a patient with the death they want without having to deal with the difficult
problems they would face if they deliberately killed that person.
”
).
22
.
See
Hinman
,
supra
note
12
, at 103.
23
.
See Active and Passive Euthanasia
,
supra
note
21
(
“
But some people think this
distinction is nonsense, since stopping treatment is a deliberate act, and so is deciding not to
carry out a particular treatment.
”
).
24
.
See
id.
Even though the disease of the patient is an underlying factor in the patient
’
s
death, it cannot be argued that the doctor
’
s act of turning off life
-
sustaining equipment is the
17
Illinois Death with Dignity
Act
2014
passively letting a patient die by removing life
-
support is just as much of an
act as is administering a lethal injection to a patient.
25
Therefore, there i
s no
material difference between active and passive euthanasia because in both
instances the patient dies from an affirmative action that was taken for
humanitarian reasons.
26
At times active euthanasia is preferable to passive euthanasia.
27
Active
euthanasi
a is often more compassionate that passive euthanasia.
28
The
typical case is one in which a patient is dying of an incurable disease and
his pain and suffering can no longer be alleviated by the present treatment.
29
The patient will inevitably die within the next few days, but he cannot bear
to go on living because of the excruciating pain.
30
The patient asks the
doctor to end his life, and his family supports his request.
31
At this point in
time, a doctor can withhold
treatment and let the patient die, passive
proximate cause of the patient
’
s death.
25
.
See id.
(
“
[T]he act of removing life
-
support is just as much an act of killing as
giving a lethal injection.
”
).
26
.
Id.
27
.
See
Rachels,
supra
note
18
for a good distinction between active and passive
euthanasia. Throughout the article Rachels suggests that there is no moral difference
between active and passive euthanasia because the end result is the same: the patient dies.
Id.
“
The bare difference be
tween killing [active euthanasia] and letting die [passive euthanasia]
does not, in itself make a moral difference. If a doctor lets a patient die, for humane reasons,
he is in the same moral position as if he had given the patient a lethal injection for h
umane
reasons.
”
Id.
In the early 1970
’
s AMA policy stated that intentional termination of a patient
’
s
life was wrong and then goes on to deny that removing life
-
sustaining treatment was the
intentional termination of a life.
Id.
Yet, it is a mistake to den
y that the cessation of treatment
is the
“
intentional termination of the life of one human being by another.
”
Id.
Therefore,
there can be no moral distinction between active and passive euthanasia.
“
If one simply
withholds the treatment, it may take the pa
tient longer to die, and so he may suffer more than
he would if more direct action were taken and a lethal injection given.
”
Id.
at 121.
28
.
Hinman,
supra
note
12
, at 103.
29
.
Id.
30
.
Id.
31
.
See
Rachels,
supra
note
18
. Suppose a patient is going to die in a few days and the
current treatment is not alleviating any pain. The doctor can withhold treatment.
Id.
However, the patient
’
s agony will continue on needlessly.
Id.
If the doctor simply withholds
treatment, the pati
ent would suffer more that if a more direct action, such as lethal injection
were taken.
Id.
This is a strong reason for thinking that once the decision to not continue
treatment has been made, that active euthanasia is preferable, more humane and
compassi
onate than passive euthanasia.
See also
Hinman, at 103. (
“
It is not uncommon for
situations to occur in which patients will undoubtedly die
.
.
.
their remaining time will be
filled
.
.
.
with extreme pain or unconsciousness
.
.
.
.
In such situations, pas
sive euthanasia
seems to be
crueler
than active euthanasia and therefore morally less preferable.
”
).
Vol. 23
Annals of Health Law
18
euthanasia, or he can take steps to end the patient’s suffering, active
euthanasia.
32
Currently, only the former is legal in Illinois.
33
B.
Assisted v
ersus Unassisted Euthanasia
It is also important to highlight the d
istinction between assisted and
unassisted euthanasia. The difference is important because state initiatives
that call for physician assisted suicide that have been accepted have
legislated a form of unassisted euthanasia.
34
The states conditioned their
law
s on the patients’ ability to personally take the death causing medication
himself.
35
While the state initiatives that call for physician assisted suicide
that have failed attempted to legislate a form of active euthanasia.
36
These
initiatives have failed be
cause if a patient is unable to self
-
administer the
death
-
hastening medication, a physician cannot actively assist the patient,
because this act would be illegal.
37
Therefore, physician
-
assisted suicide is a
misnomer because the only physician assistance co
mes writing a
prescription for a death
-
hastening medication.
38
32
.
Rachels,
supra
note
18
.
33
.
Compare In re Longeway
, 549 N.E.2d 292, 321 (Ill. 1989) (holding that
guardian of
an incompetent patient who is terminally ill and diagnosed as irreversibly comatose
may
exercise
right
to
refuse artificial nutrition and hydration on behalf of the patient),
and Ficke
v. Evangelical Health Sys.
, 674 N.E. 2d 888, 889 (Ill. App. Ct. 1996) (
“
As a general
principle of Illinois law, competent adults have the
right
to
refuse a
ny type of medical
care
,
including
life
-
sustaining
treatment. The
right
to
refuse medical
care
has been recognized
under constitutional
right
-
to
-
privacy principles and is deeply ingrained in common law
principles of individual autonomy, self
-
determination,
and informed consent
.
”
),
with
720 Ill.
Comp. Stat. Ann. 5/12
-
34.5 (2012) (making it a crime for someone to aid another person in
the physical act of committing suicide).
34
.
See
Y
UILL
,
supra
not
e
12
, at 29. One major difference between Oregon
’
s successful
Measure 16 and the defeated Washington initiative 119
and California
’
s Proposition 161,
was that th
e Oregon proposal explicitly prohibited euthanasia: it was
reasonable
‘
prescribing
only
’
measure that barred any kind of lethal injection or other direct action on a
dying patient
by the physician. This difference was critical to the bill
’
s success becau
se it silenced the
euthanasia threat to certain groups fostered by the opposition by exclusively endorsing
the death
-
by
-
prescription model.
35
.
See
O
R
.
R
EV
.
S
TAT
.
§§ 127.800
-
127.897 (2013)
(requiring a terminally ill patient to
be able to self
-
administer a DWDA prescription).
36
.
See supra
note
34
and accompanying note.
37
.
See supra
note
35
.
38
.
Oregon Health Authority,
Death With Dignity Act
,
O
REGON
.
GOV
,
19
Illinois Death with Dignity
Act
2014
III.
O
REGON
’
S
D
EATH WITH
D
IGNITY
A
CT
In 1997, Oregon became the first state to legalize physician
-
assisted
suicide
39
when it enacted the DWDA.
40
The DWDA allows terminally
-
ill
patients to end their lives through voluntary self
-
administration of lethal
medications that are prescribed by a physician.
41
Oregon’s DWDA is a
form of physician
-
assisted suicide and not a form of voluntary active
euthanasi
a.
42
The distinguishing feature of physician
-
assisted suicide is that
the drugs are to be self
-
administered by the patient.
43
This distinction allows
a physician to distance himself from a patient’s action and be legally
protected from liability for assistin
g in his suicide.
44
A. How t
he DWDA Works
If an Oregon resident is a capable adult who is confirmed terminal by his
attending and consulting physicians, and voluntarily expressed his wish to
die, then he may make a written request for medication that will e
nd his life
in a humane and dignified matter.
45
The DWDA qualifies and defines what
it means to be a capable adult
46
; the patient must be determined to be able to
make and communicate his healthcare decisions to his healthcare
providers.
47
Furthermore, the DW
DA defines what it means to be terminally
http://public.health.oregon.gov/ProviderPartnerResources/EvaluationResearch/DeathwithDig
nityAct/Pages/index.aspx (last visited Fed. 25, 2014) (
“
Death with Dignity Act which allows
terminally
-
ill Oregonians to end their lives through the voluntary self
-
administration of
lethal medications, expressly prescribed by a physician for that purpose.
”
).
39
.
See Euthanasia
,
P
ROCON
.
ORG
, http://euthanasia.procon.org/view.resource.php?
resourceID=000132 (last updated Dec. 13, 2013). Currently four states have legalized
physician
-
assisted suicide: three states, Oregon, Virginia, and Washington, have done so by
enacting legislation, and;
one state, Montana, has done so via court ruling.
Id.
40
.
O
R
.
R
EV
.
S
TAT
.
§§ 127.800
-
127.897 (2013).
41
.
See
Oregon Health Authority,
supra
note
38
.
42
.
See supra
Part II for a discussion about the differences between physician
-
assisted
suicide and euthanasia.
43
.
Young,
supra
note
12
, at 45.
44
.
Id.
45
.
O
R
.
R
EV
.
S
TAT
.
§ 127.805.
46
.
Id.
at § 127.800(3).
47
.
See id
.
at § 127.800. The court or the patient
’
s attending or consulting physician,
Vol. 23
Annals of Health Law
20
ill
48
; a patient will be diagnosed terminal if he suffers from an incurable or
irreversible disease that has been medically confirmed and the patient,
within reasonable medical judgment, will die within six months.
49
B. Procedural Safeguards
The DWDA sets out numerous procedural safeguards to ensure that the
patient’s request to die is well
-
informed, his own, and has not been made in
a rash or hasty manner.
50
In order to provide adequate protection for a
competent term
inally
-
ill patient, the DWDA requires that the patient must
make a valid request for life
-
ending medication.
51
The patient must make
the request in front of two witnesses, and the witnesses must be able to
attest that the patient signed his written request
free from coercion and
volitionally.
52
To further ensure that a patient has not been coerced in any
way, the DWDA limits the qualifications of valid witnesses to a patient’s
written request.
53
The witness cannot be a relative, by blood or adoption,
cannot be
entitled to any portion of the patient’s estate, cannot be the
owner, operator or employee of the center in which the patient is receiving
medical care and cannot be the patient’s attending physician.
54
The DWDA also protects a patient from making a rash d
ecision by
requiring him to make an oral request, followed by a written request,
followed by a second oral request, all within fifteen days.
55
After the patient
makes his second oral request, his attending physician must offer the patient
psychiatrist or psychologist can determine if the patient has the ability to express his wishes.
Id.
48
.
Id.
at § 127.800(12).
49
.
Id.
50
.
See id.
at §§ 127.805
-
127.850.
51
.
See id.
at §§ 127.805
-
127.810.
52
.
Id.
at § 127.810.
53
.
See id.
54
.
Id.
55
.
Id.
at § 127.840.
21
Illinois Death with Dignity
Act
2014
the opportunity to
rescind his request.
56
No less than fifteen days may
elapse between the patient’s initial oral request and the writing of a
prescription for medicine that will end the patient’s life in a humane and
dignified manner, and no less than forty
-
eight hours shal
l elapse between
the patient’s written request and the writing of a prescription.
57
In the
interim, the patient’s attending physician must fully inform the patient of
his decision
58
and must recommend that the patient notify his next of kin
that he made a re
quest for life
-
ending medication.
59
The last protection that
the DWDA provides to a patient is that he must self
-
administer the
medication
60
; this protection prevents a doctor or a family member from
administering the death
-
hastening drug to the patient.
61
If
the patient wants
to die, then he must self
-
administer the drug.
62
IV.
P
ROPOSED
I
LLINOIS
D
EATH WITH
D
IGNITY
A
CT
The Illinois legislature should propose a Death with Dignity Act that
models after Oregon’s DWDA
63
; however, Illinois should go a step further
and also legalize active euthanasia. Illinois lacks a legitimate state interest
in forcing a capable, terminally
-
ill adult, who wishes to be aided in the act
of committing suicide, to live the rest of his days in agony and despair.
64
Additionally, terminall
y
-
ill patients’ choices have grave impacts on those
that are intimately connected to them, and therefore any decision relating to
a terminally
-
ill patient’s final requests should be between him and his
56
.
Id.
at §§ 127.840
-
127.845.
57
.
Id.
at § 127.850.
58
.
Id.
at § 127.830.
59
.
Id.
at § 127.835.
60
.
See
Or
egon Health Authority,
supra
note
38
(
“
[A]llows terminally ill Oregonians to
end their lives through the voluntary self
-
administration of lethal medications
.
.
.
.”
).
61
.
Id.
62
.
Id.
63
.
O
R
.
R
EV
.
S
TAT
.
§§ 127.800
-
127.897 (2013).
64
.
But see
Washington v. Glucksberg, 521 U.S. 702, 728
-
36 (1997) (in holding that
Washington
’
s assisted suicide ban does not violate the Constitution, the Court stated that
Washington asserted se
veral legitimate reasons for banning assisted
-
suicide).
Vol. 23
Annals of Health Law
22
family and not a concern of the State.
65
A. Illinois Do
es Not Have an Unqualified Interest i
n Extending the Lives of
its Residents
Illinois does not have an unqualified interest in preserving the lives of its
residents despite the holding of
Washington v. Glucksberg
, in which the
Supreme Court found that Washi
ngton did have this interest.
66
Washington
had a legitimate interest because the patients in
Washington
were asserting
an interest absent a state statute; however, if Illinois were to propose a
statute allowing for physician
-
assisted suicide and active euth
anasia, then
that statute would qualify Illinois’ interests in its terminally ill patients.
67
A
state may have an interest in preserving the lives of citizens that are still
productive to society, but this interest must be weighed against the medical
condit
ions and the wishes of patients.
68
This balancing approach is better
because end
-
of
-
life care is costly
69
; an uninsured terminally
-
ill patient who
wishes to die may end up needlessly costing the state thousands of dollars
in order to prolong the patient’s li
fe for a few more days or weeks.
70
Further, if a patient requests medication to end his life and Illinois law
continues to forbid it, then it appears that Illinois is mandating the suffering
of terminally ill patients.
71
65
.
See infra
Part IV.B.
66
.
Glucksberg
, 521 U.S. at 728 (
“
First, Washington has an
‘
unqualified interest in the
preservation of human life.
’
Id
. The State
’
s prohibition on assisted suicide, like all homicide
laws both reflects and advances its commitment to this interest.
”
[
citations omitted
]).
67
.
Id.
The holding
Washington v. Glucksberg
was valid and can be distinguished from
what I am proposing because in
Washington
the plaintiffs were asserting that the patients had
a right to die absent a state stat
ute; therefore the standard for review was that Washington
had a compelling state interest.
Id
. If Illinois were to pass a DWDA, then the compelling
state interest is legislated into the Act.
Id
.
68
.
See id.
at 729 (
“
[T]he State has a real interest in preserving the lives of those who
can still contribute to society and have the potential to enjoy life.
”
). The court of appeals
went on to say that Washington
’
s interests must be weighed against the
“
medical condition
and the wishes of the person whose life is at stake.
”
Id.
69
.
See
Gorenstein,
supra
note
3
and accompanying text.
70
.
Id.
71
.
See
Rita L. Marker & Kathi Hamlon,
Euthanasia and Assisted Suicide: Frequently
23
Illinois Death with Dignity
Act
2014
Critics of this assertion and defende
rs of banning physician
-
assisted
suicide and active euthanasia argue that the laws are in place to prevent
abuse and protect the patient.
72
In response to critics, the Oregon DWDA
has procedural safeguards in place to ensure that a patient wishing to die is
not taken advantage of by unscrupulous doctors or being coerced by family
members.
73
Meanwhile, the DWDA allows a patient to have full autonomy
in making the critical decision on how to spend his final moments.
74
If
Illinois legislated physician
-
assisted su
icide, modeled after Oregon’s
DWDA and all of the procedural safeguards that come with it, it would
ensure that a patient in Illinois would not be taken advantage of.
75
Additionally, if Illinois were to give a terminal patient the choice to end his
life wit
h dignity, it does not necessarily follow that he will choose to end
his life.
76
B. A Terminally
-
Ill Pa
tient’s Care Impacts Those Who are Connected t
o
Them
Illinois’ terminally
-
ill patients should have the option to be assisted in
suicide by their physician
or be actively administered life
-
ending drugs if
they are unable to physically act themselves because their choices and
decisions have a grave impact on those around them.
77
As people get older
Asked
Questions
,
P
ATIENTS
R
IGHTS
C
OUNCIL
,
http://www.patientsrightscouncil.org/site
/frequently
-
asked
-
questions/ (last visited Feb. 26, 2014) (
“
Activists often claim that laws
against euthanasia and assisted suicide are government mandated suffering.
”
).
72
.
Id.
(“
Laws against euthanasia and assisted suicide are in place to prevent abuse and
to protect people from unscrupulous doctors and others. They are not, and never have been,
intended to make anyone
suffer.”).
73
.
See infra
Part IV.B.
74
.
Id.
75
.
See supra
Part III.B.
76
.
See
O
REGON
P
UBLIC
H
EALTH
D
IVISION
,
2013
DWDA
R
EPORT
(2014),
available at
http://public.health.oregon.gov/ProviderPartnerResources/EvaluationResearch/DeathwithDig
nityAct/Documents/yeay16.pdf. S
ince the DWDA was passed in Oregon, a total of 1,173
people have received prescriptions written under the DWDA, while only 752 patients have
died from taking the medications.
Id.
77
.
See
John Har
dwig,
Is There a Duty to Die?
, 27 Hastings Ctr. Report 34 (1997),
reprinted in
Contemporary Moral Issues: Diversity and Consensus 110 (Lawrence M.
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