Editing Right to die (section)

==By country==
{{See also|Voluntary euthanasia#By country}}
[[File:Legality of euthanasia.svg|thumb|350px|right|Status of euthanasia around the world:
{{Legend|#0000ffff|Active voluntary euthanasia legal ([[Belgium]], [[Canada]], [[Colombia]], [[Ecuador]], [[Luxembourg]], the [[Netherlands]], [[New Zealand]], [[Spain]] and the Australian states of [[New South Wales]], [[Queensland]], [[South Australia]], [[Tasmania]], [[Victoria (Australia)|Victoria]] and [[Western Australia]])}}
{{Legend|#00afffff|Passive euthanasia legal (refusal of treatment / withdrawal of life support)}}
{{Legend|#ddddddff|Active euthanasia illegal, passive euthanasia not legislated or regulated}}
{{Legend|#c60000ff|All forms of euthanasia illegal}}
]]
[[File:Legality of assisted suicide.svg|thumb|350px|right|Current status of assisted suicide around the world:
{{Legend|#0000ffff|Physician-assisted suicide is legal.}}
{{Legend|#00b4ffff|Legalized by court ruling, but not legislated or regulated}}
{{Legend|#C0C0C0|Physician-assisted suicide is illegal.}}
]]
As of 2023, some forms of voluntary euthanasia are legal in [[Australia]], [[Belgium]],<ref name=law>{{cite news|url=http://news.bbc.co.uk/2/hi/health/2600923.stm |title=Euthanasia and the law |publisher=BBC News |date=23 December 2002 |first=Ursula |last=Smartt | name-list-style = vanc }}</ref> [[Canada]],<ref name=canada/> [[Colombia]],<ref name=canada/> [[Luxembourg]],<ref>{{Cite web|url=http://euthanasia.procon.org/view.resource.php?resourceID=000136#Luxembourg|title=Euthanasia & Physician-Assisted Suicide (PAS) around the World|date=2016-07-20|website=euthanasia.procon.org – Euthanasia– ProCon.org|access-date=2017-04-19|archive-date=2019-03-30|archive-url=https://web.archive.org/web/20190330093516/https://euthanasia.procon.org/view.resource.php?resourceID=000136#Luxembourg|url-status=dead}}</ref> the [[Euthanasia in the Netherlands|Netherlands]],<ref name=law/> [[New Zealand]], [[Spain]] and [[Switzerland]].<ref name=law/>

=== Australia ===
{{Main|Euthanasia in Australia}}
As euthanasia is a health issue, under the Australian constitution this falls to [[States and territories of Australia|state and territory governments]] to legislate and manage.

Euthanasia was legal within the [[Northern Territory]] during parts of 1996–1997 as a result of the territory parliament passing [[Rights of the Terminally Ill Act 1995]]. As a territory and not a state, the federal government under [[Prime Minister of Australia|Prime Minister]] [[John Howard]] amended the [[Northern Territory (Self-Government) Act 1978]] (amongst others) to ensure that territories of Australia are no longer able to legislate on euthanasia.<ref>{{Cite web|url=https://www.abc.net.au/news/2019-06-18/euthanasia-northern-territory-victoria-marshall-perron-debate/11220008|title=As Victoria brings in euthanasia, NT is still banned from talking about it|last=Garrick|first=Matt|date=2019-06-18|website=ABC News|language=en-AU|access-date=2019-06-25}}</ref> However, this was repealed in December 2022 with the passing of Restoring Territory Rights Act. The federal government is not able to legislate restrictions on health issues for the Australian states and territories in the same manner.<ref>{{Cite web|url=https://www.parliament.nsw.gov.au/about/Pages/The-Roles-and-Responsibilities-of-Federal-State-a.aspx|title=The Roles and Responsibilities of Federal, State and Local Governments|website=www.parliament.nsw.gov.au|access-date=2019-06-25}}</ref>

Voluntary assisted dying schemes have been in effect in the following states; [[Victoria (Australia)|Victoria]] since 19 June 2019,<ref>{{Cite web |url=https://www.theage.com.au/national/victoria/we-re-on-the-right-side-of-history-victoria-s-assisted-dying-laws-come-into-effect-for-terminally-ill-20190619-p51z5x.html |title='We're on the right side of history': Victoria's assisted dying laws come into effect for terminally ill |last=Cunningham |first=Melissa |date=2019-06-19 |website=The Age |language=en |access-date=2019-06-26 |archive-url=https://web.archive.org/web/20190626032133/https://www.theage.com.au/national/victoria/we-re-on-the-right-side-of-history-victoria-s-assisted-dying-laws-come-into-effect-for-terminally-ill-20190619-p51z5x.html |archive-date=26 June 2019 |url-status=live}}</ref> [[Western Australia]] since 1 July 2021,<ref>{{Cite web | url=https://ww2.health.wa.gov.au/voluntaryassisteddying | title=Voluntary Assisted Dying}}</ref> [[Tasmania]] since 23 October 2022,<ref name=Tas23Oct2022>{{cite web|url=https://www.abc.net.au/news/2022-10-23/tasmania-voluntary-assisted-dying-laws-come-into-effect/101550264|title=Tasmania's voluntary assisted dying laws come into effect today. Here's how they will work|work=ABC News|date=23 October 2022|author=Will Murray}}</ref> [[Queensland]] since 1 January 2023,<ref>{{cite web|url=https://www.sbs.com.au/news/article/voluntary-assisted-dying-is-now-legal-in-queensland-heres-what-you-need-to-know/9lzfjxve2|title=Voluntary assisted dying is now legal in Queensland. Here's what you need to know|work=SBS News|date=1 January 2023}}</ref> and [[South Australia]] since 31 January 2023.<ref name=SA31Jan2023>{{cite web|url=https://www.abc.net.au/news/2023-01-31/sa-voluntary-assisted-dying-laws-take-effect-in-sa/101901158|title=Voluntary assisted dying scheme becomes available to eligible patients in South Australia|author=Isabel Dayman|date=31 January 2023|work=ABC News}}</ref> [[New South Wales]] was the final state to pass legislation for assisted dying in May 2022, which went into effect on 28 November 2023.<ref>{{cite web|url=https://www.health.nsw.gov.au/voluntary-assisted-dying|title=Voluntary assisted dying|work=NSW Government}}</ref>

=== Belgium ===
{{Main|Euthanasia in Belgium}}
In 2002, the Belgian parliament legalized euthanasia.<ref>{{Cite journal|last1=Wal|first1=Gerrit van der|last2=Deliens|first2=Luc|date=2003-10-11|title=The euthanasia law in Belgium and the Netherlands|url=https://www.thelancet.com/journals/lancet/article/PIIS0140-6736(03)14520-5/abstract|journal=The Lancet|language=en|volume=362|issue=9391|pages=1239–40|doi=10.1016/S0140-6736(03)14520-5|issn=0140-6736|pmid=14568754|s2cid=42196605|url-access=subscription}}</ref>

=== Canada ===
{{main|Euthanasia in Canada}}

In August 2011, a [[British Columbia]] [[B.C. Supreme Court|Supreme Court]] judge requested to speed up a right to die lawsuit so that [[Gloria Taylor (patient)|Gloria Taylor]] could have a doctor assist her in dying by suicide. She had [[Lou Gehrig's disease]].<ref>{{cite news |url=https://www.cbc.ca/news/canada/british-columbia/b-c-court-asked-to-fast-track-right-to-die-lawsuit-1.1023576|title=B.C. court asked to fast-track right-to-die lawsuit|date=2 August 2011|access-date=14 December 2014|publisher=CBC News}}</ref> She died of an infection in 2012.<ref>{{cite web |title=Assisted-suicide crusader Gloria Taylor dies in B.C. |url=https://www.cbc.ca/news/canada/british-columbia/assisted-suicide-crusader-gloria-taylor-dies-in-b-c-1.1164650 |website=CBC News |access-date=16 June 2023}}</ref>

On February 6, 2015, the [[Supreme Court of Canada]] ruled that denying the right to assisted suicide was unconstitutional. The court's ruling limits physician-assisted suicides to "a competent adult person who clearly consents to the termination of life and has a grievous and irremediable medical condition, including an illness, disease or disability, that causes enduring suffering that is intolerable to the individual in the circumstances of his or her condition." The ruling was suspended for 12 months to allow the Canadian parliament to draft a new, constitutional law to replace the existing one.<ref>[https://www.theglobeandmail.com/news/national/supreme-court-rules-on-doctor-assisted-suicide/article22828437/ Supreme Court rules Canadians have right to doctor-assisted suicide] Sean Fine, Globe and Mail 6 Feb. 2015</ref> The court decision includes a requirement that there must be stringent limits that are "scrupulously monitored." This will require the death certificate to be completed by an independent medical examiner, not the treating physician, to ensure the accuracy of reporting the cause of death.<ref>{{cite news | vauthors = Guichon J, Alakija P, Doig C, Mitchell I, Thibeault P |url=https://www.theglobeandmail.com/globe-debate/assisted-dying-four-problems-one-simple-solution/article27924838/|title=Assisted dying: Four problems, one simple solution |date=28 December 2015|newspaper=Globe and Mail|location=Toronto, Canada|access-date=2 January 2016}}</ref> The [[Canadian Medical Association]] (CMA) reported that not all doctors were willing to assist in a patient's death due to legal complications and went against what a physician stood for. Many physicians stated that they should have a voice when it comes to helping a patient end their life.<ref>{{cite journal | vauthors = Vogel L | title = Top court hears right-to-die appeal | journal = CMAJ | volume = 186 | issue = 17 | pages = 1284 | date = November 2014 | pmid = 25332368 | pmc = 4234712 | doi = 10.1503/cmaj.109-4923 }}</ref> However, the belief in late 2015 was that no physician would be forced to do so but the CMA was offering educational sessions to members as to the process that would be used.<ref>{{cite web|url=http://www.ctvnews.ca/health/canadian-doctors-express-mixed-opinions-on-assisted-dying-1.2715008|title=Canadian doctors express mixed opinions on assisted dying | date=27 December 2015|website=CTV News|publisher=Bell Media|access-date=2 January 2016|author=The Canadian Press}}</ref>

On June 17, 2016, legislation passed both houses of the [[Parliament of Canada]] and received [[Royal Assent]] to allow euthanasia within Canada.<ref>{{Cite web |url=http://www.her.ie/news/canada-legalises-euthanasia-for-the-terminally-ill/298541 |title=Canada legalises euthanasia for the terminally ill |last=Keane |first=Rebecca |name-list-style=vanc |date=20 June 2016 |website=Her.ie |publisher=Maximum Media; Dublin, Ireland |access-date=22 June 2016 |archive-date=16 August 2016 |archive-url=https://web.archive.org/web/20160816091726/http://www.her.ie/news/canada-legalises-euthanasia-for-the-terminally-ill/298541 |url-status=dead }}</ref><ref name=canada>{{Cite web|url=https://www.thestar.com/news/canada/2016/06/17/senate-votes-not-to-send-assisted-dying-bill-back-to-mps.html |title=Assisted dying to become law after Senate backs Liberals' bill |last=MacCharles |first=Tonda | name-list-style = vanc |date=17 June 2016 |website=thestar.com |publisher=Toronto Star |access-date=16 July 2016}}</ref>

=== Colombia ===
{{Main|Legality of euthanasia#Colombia}}
On 20 May 1997, the [[Constitutional Court of Colombia]] decriminalised piety homicide, for terminally ill patients, stating that "the medical author cannot be held responsible for the assisted suicide of a terminally ill patient" and urged [[Congress of Colombia|Congress]] to regulate [[voluntary euthanasia|euthanasia]] "in the shortest time possible".<ref>{{Cite web|url=http://www.dmd.org.co/pdf/sentencia-c-239.pdf|archive-url=https://web.archive.org/web/20161124160354/http://www.dmd.org.co/pdf/sentencia-c-239.pdf|url-status=dead|archive-date=November 24, 2016|title=REPÚBLICA DE COLOMBIA Corte Constitucional Sentencia No. C-239/97|author=Constitutional Court of Colombia|date=20 May 1997|access-date=24 November 2016|author-link=Constitutional Court of Colombia}} (in Spanish)</ref>

On 15 December 2014, the Constitutional Court had given the [[Ministry of Health and Social Protection (Colombia)|Ministry of Health and Social Protection]] 30 days to publish guidelines for the healthcare sector to use in order to guarantee terminally ill patients, with the wish to undergo euthanasia, their right to a dignified death.<ref>{{cite web|url=http://www.elespectador.com/vivir/los-principios-regular-eutanasia-articulo-544675|title=Los principios para regular la eutanasia|publisher=ElEspectador.com|date=19 February 2015|author=Redacción Salud|language=es}}</ref>

=== Germany ===
In February 2020, the [[Federal Constitutional Court]] ruled that the [[right to personal identity]] in German constitutional law encompasses a right to self-determined death, which in turn contains a right to suicide. Notably, this right is not limited to terminally ill patients, instead finding its limits within the requirement for the choice to be autonomous.<ref>{{Cite web|title=Bundesverfassungsgericht - Press - Criminalisation of assisted suicide services unconstitutional|url=https://www.bundesverfassungsgericht.de/SharedDocs/Pressemitteilungen/EN/2020/bvg20-012.html|access-date=2021-01-30|website=www.bundesverfassungsgericht.de}}</ref> The ruling has sparked controversy, with opponents arguing that the ruling may enable peer pressure into assisted suicide.<ref>{{Cite news|last=Müller|first=Reinhard|title=Nach Sterbehilfe-Urteil: Ein Dammbruch droht|language=de|work=FAZ.NET|url=https://www.faz.net/1.6652287|access-date=2021-01-30|issn=0174-4909}}</ref>

=== India ===
{{main|Euthanasia in India}}

Since 2018, the Supreme Court of India has legalized passive euthanasia in India during a case involving [[Aruna Shanbaug]] under strict conditions, namely that the patient's consent (or relatives) is needed, and that the patient must be terminally ill or vegetative state.

=== Netherlands ===
{{main|Euthanasia in the Netherlands}}
The [[Netherlands]] legalized [[voluntary euthanasia]] in 2002. Under Dutch law, euthanasia and assisted suicide can only be performed by doctors, and that is only legal in cases of ''"hopeless and unbearable"'' suffering. In practice, this means that it is limited to those with serious and incurable medical conditions (including [[mental illness]]) and in considerable suffering like pain, hypoxia or exhaustion. Helping somebody to die by suicide without meeting the qualifications of the Dutch euthanasia law is illegal.<ref name="Buiting-2009">{{cite journal | vauthors = Buiting H, van Delden J, Onwuteaka-Philpsen B, Rietjens J, Rurup M, van Tol D, Gevers J, van der Maas P, van der Heide A | title = Reporting of euthanasia and physician-assisted suicide in the Netherlands: descriptive study | journal = BMC Medical Ethics | volume = 10 | pages = 18 | date = October 2009 | pmid = 19860873 | pmc = 2781018 | doi = 10.1186/1472-6939-10-18 | doi-access = free }}</ref> These criteria concern the patient's request, the patient's suffering (unbearable), the infaust prognosis (hopeless), the information provided to the patient, the absence of reasonable alternatives, consultation of another physician and the applied method of ending life.<ref name="Buiting-2009"/>

===New Zealand===
{{main|Euthanasia in New Zealand}}
Euthanasia is legal in New Zealand. In 2015, a lawyer with cancer [[Lecretia Seales]] brought a case (''[[Seales v Attorney-General]]'') to the [[High Court of New Zealand|High Court]] to challenge [[New Zealand law]] for her right to die with the assistance of her GP, asking for a declaration that her GP would not risk conviction.<ref>{{cite news|title=Lecretia Seales: Lawyer with cancer embarks on challenge to New Zealand's euthanasia laws|url=http://www.abc.net.au/news/2015-04-10/new-zealand-lawyer-embarks-on-euthanasia-legal-challenge/6385148|access-date=5 June 2015|publisher=[[Australian Broadcasting Corporation]]}}</ref><ref>{{cite news|url=http://www.radionz.co.nz/news/national/274807/judge-thanks-woman-for-right-to-die-case |title=Judge thanks woman for right-to-die case |access-date=5 June 2015|publisher=[[Radio New Zealand]]}}</ref> However [[End of Life Choice Act 2019|legislation]] to legalize euthanasia for terminally ill patients was voted upon in the 2020 general election and was voted in favour of legalisation. The End Of Life Choice Bill took effect on 7 November 2021.

===Peru===
Peru legally forbids euthanasia.<ref name="APPeru">{{cite news |publisher=[[The Associated Press]] |title=Terminally ill Peru woman demands right to euthanasia |date=February 7, 2020 |url=https://apnews.com/71bd93563e20c477461a29fe5ed9d046}}</ref> In 2020, a legal challenge to the law was launched by Ana Estrada, aimed at decriminalizing the practice.<ref name="APPeru"/>

=== United States ===
{{main|Euthanasia in the United States|Assisted suicide in the United States}}

The term ''right to die'' has been interpreted in many ways, including issues of suicide, passive euthanasia, active euthanasia, assisted suicide, and physician-assisted suicide.<ref>{{cite web|url=https://law.justia.com/constitution/us/amendment-14/04-due-process-of-law.html|title=Due Process of Law|website=Justia Law|access-date=17 February 2019}}</ref>

In the United States, public support for the right to die by physician-assisted suicide has increased over time. In a 2005 survey, the Pew Research Center found that 70% of participants say that there are circumstances in which a patient should be allowed to die; however, only 46% of participants approved of laws permitting doctors to assist patients in ending their lives.<ref>{{Cite web|date=January 5, 2006|title=Strong Public Support for Right to Die|url=https://www.pewresearch.org/politics/2006/01/05/strong-public-support-for-right-to-die/|website=Pew Research Center}}</ref> In May 2018, a Gallup poll report announced that 72% of responders said that doctors should legally be allowed to help terminally ill patients die.<ref>{{Cite web|date=May 31, 2018|title=Americans' Strong Support for Euthanasia Persists|url=https://news.gallup.com/poll/235145/americans-strong-support-euthanasia-persists.aspx|website=Gallup}}</ref> However, framing effects of using language such as "suicide" rather than "ending one's life" have the potential to lower approval rates by 10-15%.<ref name=":2">{{Cite journal|last1=Emanuel|first1=Ezekiel J.|last2=Onwuteaka-Philipsen|first2=Bregje D.|last3=Urwin|first3=John W.|last4=Cohen|first4=Joachim|date=2016-07-05|title=Attitudes and Practices of Euthanasia and Physician-Assisted Suicide in the United States, Canada, and Europe|url=https://doi.org/10.1001/jama.2016.8499|journal=JAMA|volume=316|issue=1|pages=79–90|doi=10.1001/jama.2016.8499|pmid=27380345|issn=0098-7484|url-access=subscription}}</ref>

A 2014 survey of physicians revealed that 54% of respondents agreed that physician-assisted suicide should be allowed.<ref name=":2" /> In a rigorous survey of physicians in 1996, less than 20% of physicians reported that they received requests from patients to be euthanized, and less than 5% complied.<ref>{{Cite journal|last1=Meier|first1=D. E.|last2=Emmons|first2=C. A.|last3=Wallenstein|first3=S.|last4=Quill|first4=T.|last5=Morrison|first5=R. S.|last6=Cassel|first6=C. K.|date=1998-04-23|title=A national survey of physician-assisted suicide and euthanasia in the United States|journal=The New England Journal of Medicine|volume=338|issue=17|pages=1193–1201|doi=10.1056/NEJM199804233381706|issn=0028-4793|pmid=9554861|doi-access=free}}</ref> In 2020, the Oregon Death with Dignity Act data summary revealed that the number of prescriptions for lethal doses of medications increased by 25% since 2019, and have been steadily increasing since 1998.<ref name=":3">{{Cite web|title=Oregon Health Authority : Death with Dignity Act Annual Reports : Death with Dignity Act : State of Oregon|url=https://www.oregon.gov/oha/ph/ProviderPartnerResources/EvaluationResearch/DeathwithDignityAct/Pages/ar-index.aspx|access-date=2021-09-13|website=www.oregon.gov}}</ref> Of patients who received these prescriptions, 66% eventually died from ingesting the medications.<ref name=":3" />

==== Major right to die cases ====

=====Karen Quinlan=====
The right to die movement in the United States began with the case of [[Karen Ann Quinlan|Karen Quinlan]] in 1975 and continues to raise bioethical questions about one's quality of life and the legal process of death. Quinlan, 21, lost consciousness after consuming alcohol and tranquilizers at a party.<ref name="McFadden_1985">{{cite web | vauthors = McFadden RD | title = Karen Ann Quinlan, 31, Dies; Focus of '76 Right to Die Case | url = https://www.nytimes.com/1985/06/12/nyregion/karen-ann-quinlan-31-dies-focus-of-76-right-to-die-case.html | work = The New York Times | date = 12 June 1985 }}</ref> She soon began to experience respiratory problems, which then prevented oxygen from flowing to her brain. That led her to slip into a comatose state in which a respirator and a feeding tube were used to keep her alive and breathing.<ref name="Cornachio_1989" /><ref name="McFadden_1985" /> Quinlan did not have a proxy or living will and had not expressed her wishes if something ever happened to her to those around her, which made it difficult to decide what the next step should be.

Quinlan's parents understood that their daughter would never wake up and that prolonging her life may be more damaging and it would not be of quality life.<ref name="McFadden_1985" /><ref name="pmid4018757" /> Her father sought out the right to be Quinlan's legal guardian and petitioned for the removal of the respirator that was keeping her alive. The court, however, argued that the removal of the ventilator, which would lead to Quinlan's death, would be considered unlawful, unnatural, and unethical. Quinlan's lawyer made the counterargument that the removal of the respirator would allow Quinlan to have a natural death, which is natural and ethical. The Quinlans won the court case and were appointed as the legal guardians of their daughter. The respirator was removed in 1976, but Quinlan continued to live without the ventilator until 1985.<ref name="Cornachio_1989">{{cite journal | vauthors = Cornachio AW | title = The Right to Die in New York – the Controversy Lives. | journal = New York State Bar Journal | date = December 1989 | volume = 61 | issue = 8 | pages = 12–17 }}</ref><ref name="pmid4018757">{{cite journal | title = Quinlan case set pace for bioethics debate | journal = Hospitals | volume = 59 | issue = 15 | pages = 36–37 | date = August 1985 | pmid = 4018757 }}</ref> The case continues to raise bioethical questions of one's quality of life and the legal process of death. It also brings up many important issues that are still being addressed to this day.<ref name="pmid4018757" /><ref>{{Cite journal|title=Wolters Kluwer Health |journal=Critical Care Nursing Quarterly|year=2005|doi=10.1097/00002727-200501000-00009|pmid=15732427|last1=Porter|first1=T.|last2=Johnson|first2=P.|last3=Warren|first3=N. A.|volume=28|issue=1|pages=85–92|s2cid=36904123}}</ref> One of the critical points that the Quinlan case brings up is the patient's right to deny or withdraw treatment. Cases in which the patient rejected or withdrew treatment were then unheard of and went against medical ethics in preserving one's life. Debates on allowing patients the right to self-determination were controversial, and they would be evaluated for the next couple of decades from state to state. The case also brought up whether family members and those who are close to the patient are allowed in the decision-making process. Since Quinlan had no written documentation, voiced no decision, and appointed no proxy, a lengthy legal battle was caused between the Quinlan family and the state in determining Quinlan's best interest and determining if she would want to live or die. That had a significant influence on the use and establishment of advance directives, oral directives, proxies, and living wills.<ref name="pmid15732427">{{cite journal | vauthors = Porter T, Johnson P, Warren NA | title = Bioethical issues concerning death: death, dying, and end-of-life rights | journal = Critical Care Nursing Quarterly | volume = 28 | issue = 1 | pages = 85–92 | date = 2005 | pmid = 15732427 | doi = 10.1097/00002727-200501000-00009| s2cid = 36904123 }}</ref>

=====Nancy Cruzan=====
[[File:Nancy Beth Cruzan, gravestone Wellcome L0025849.jpg|thumb|207x207px|Cruzan's gravestone]]

Another major case that further propagated the right to die movement and the use of living wills, advance directives and use of a proxy was ''[[Cruzan v. Director, Missouri Department of Health]]''. In 1983, Cruzan had a car accident, which left her permanently in a vegetative state. Her status as an adult and lack of an advance directive, living will, or proxy led to a long legal battle for Cruzan's family in petitioning for the removal of her feeding tube, which was keeping her alive since the accident. Cruzan had mentioned to a friend that under no circumstances would she want to continue to live if she were ever in a vegetative state, but this was not a strong enough statement to remove the feeding tube.<ref>{{cite journal | vauthors = Greenhouse L | title = Right-to-Die Case Gets First Hearing in Supreme Court | url = https://www.nytimes.com/1989/12/07/us/right-to-die-case-gets-first-hearing-in-supreme-court.html | journal = The New York Times | date = 7 December 1989 | pages = A1, B26 | pmid = 11646739 }}</ref> Eventually, the Cruzan family won the case and had their daughter's tube removed. The case brought great debate if the right to die should be approved from state to state or as a whole nation.<ref name="Colby_2005">{{cite journal | vauthors = Colby WH | title = From Quinlan to Cruzan to Schiavo: What have we learned? | journal = Loyola University Chicago Law Journal | date = 2005 | volume = 37 | pages = 279 }}</ref>

=====Terri Schiavo=====
The [[Terri Schiavo case]] occurred between 1990 and 2005. This case was controversial due to a disagreement between Schiavo's immediate family members and her husband. In the Quinlan and Cruzan cases, the family was able to make a unanimous decision on the state of their daughters. Schiavo suffered from a cardiac arrest which led to her collapse and soon after began to have trouble breathing. The lack of oxygen to her brain caused irreversible brain damage, leaving her in a vegetative state and required a feeding tube and ventilator to keep her alive. Schiavo left no advance directive or had a discussion with her parents or husband about what she may have wanted if something were to happen to her. Soon after, her husband was appointed as her legal guardian.<ref name="Colby_2005"/>

Years later, her husband decided to remove Schiavo's feeding tube since the chances of her waking up were slim to none. Schiavo's family, however, argued against this decision and brought this case to court. The case was very turbulent and occurred over some years and involved the state and its legislators before a decision was made.<ref name = "Colby_2005" /> This brought up bioethical debates on the discontinuation of Schiavo's life vs. allowing her to continue living in a permanent vegetative state. Those who were for preserving Schiavo's life stated that removing the tube would be ethically immoral since they do not know what she would have wanted. They challenged her physical and mental state and stated that she might have some consciousness; thus she deserved to continue living. Those for removing the tube argued for self-determination and that her quality of life was diminished.<ref name = "Colby_2005" /><ref name="Koch_2005">{{cite journal | vauthors = Koch T | title = The challenge of Terri Schiavo: lessons for bioethics | journal = Journal of Medical Ethics | volume = 31 | issue = 7 | pages = 376–78 | date = July 2005 | pmid = 15994353 | pmc = 1734190 | doi = 10.1136/jme.2005.012419 }}</ref><ref name="Weijer_2005">{{cite journal | vauthors = Weijer C | title = A death in the family: reflections on the Terri Schiavo case | journal = Canadian Medical Association Journal | volume = 172 | issue = 9 | pages = 1197–98 | date = April 2005 | pmid = 15805148 | pmc = 557072 | doi = 10.1503/cmaj.050348 }}</ref> The Schiavo case is the most recent and significant right to die case that propagates the thought of having an advance directive or living will. It also further looks into other complications that can arise, such as family disagreements, which should have been accounted for when dealing with a right to die case.<ref name = "Colby_2005" /><ref name="Weijer_2005" />

;See also
* ''[[Washington v. Glucksberg]]''
* ''[[Vacco v. Quill]]''

==== Legislation ====
As the health of citizens is considered a police power left for individual states to regulate, it was not until 1997 that the US Supreme Court made a ruling on the issue of assisted suicide and one's right to die. That year, the Supreme Court heard two appeals arguing that New York (''[[Vacco v. Quill]]''<ref>{{Cite web|title=Vaco v. Quill|url=https://www.oyez.org/cases/1996/95-1858|website=Oyez}}</ref>) and Washington (''[[Washington v. Glucksberg]]<ref>{{Cite web|title=Washington v. Glucksberg|url=https://www.oyez.org/cases/1996/96-110|website=Oyez}}</ref>'') statutes that made physician-assisted suicide a felony violated the equal protection clause of the Fourteenth Amendment.<ref>{{cite web | title = Vacco, Attorney General of New York, et al. v. Quill et al.| url = https://scholar.google.com/scholar_case?case=10644975876581235704&q=vacco+v.+quill&hl=en&as_sdt=40000006 | publisher = United States Supreme Court }}</ref> In a unanimous vote, the Court held that there was no constitutional right to physician-assisted suicide and upheld state bans on assisted suicide. While in New York has maintained statutes banning physician-assisted suicide, the Court's decision also left it open for other states to decide whether they would allow physician-assisted suicide or not.

Since 1994, the following states in the US have passed assisted suicide laws: Oregon (Death with Dignity Act, 1994), Washington (Death with Dignity Act, 2008), Vermont (Patient Choice and Control at the End of Life Act, 2013), California (End of Life Option Act, 2015), Colorado (End of Life Options Act, 2016), District of Columbia (D.C. Death with Dignity Act, 2016), Hawaii (Our Care Our Choice Act, 2018), Maine (Death with Dignity Act, 2019), New Jersey (Aid in Dying for the Terminally Ill Act, 2019), and New Mexico (Elizabeth Whitefield End of Life Options Act, 2021) passed legislation that provides a protocol for the practice of physician-assisted suicide.<ref>{{cite magazine| url=https://time.com/3551560/brittany-maynard-right-to-die-laws/ | magazine=Time | first=Emily | last=Barone | name-list-style = vanc | title=See Which States Allow Assisted Suicide | date=3 November 2014}}</ref><ref>{{Cite web|title=Death with Dignity Acts|url=https://deathwithdignity.org/learn/death-with-dignity-acts/|website=Death with Dignity}}</ref> The law in these states allows terminally ill adult patients to seek lethal medication from their physicians. In 2009, the Montana Supreme Court ruled that nothing in state law prohibits physician-assisted suicide and provides legal protection for physicians in the case that they prescribe lethal medication upon patient request. In California, the governor signed a controversial physician-assisted-suicide bill, the [[California End of Life Option Act]], in October 2015 that passed during a special legislative session intended to address Medi-Cal funding,<ref>{{cite web | vauthors = Brown EG | title = A Proclamation by the Governor of California: Convene Extraordinary Session of the Legislature of the State of California | url = https://www.gov.ca.gov/docs/6.16.15_Health_Care_Special_Session.pdf | archive-url = https://web.archive.org/web/20160201231452/https://www.gov.ca.gov/docs/6.16.15_Health_Care_Special_Session.pdf | archive-date = 1 February 2016 | url-status = dead | date = 16 June 2015 }}</ref> after it had been defeated during the regular legislative session.<ref>{{cite news|url=https://www.sacbee.com/news/politics-government/capitol-alert/article33269166.html|title=Assisted-death bill passes first Assembly committee|first=Alexei|last=Koseff| name-list-style = vanc |access-date=17 February 2019|newspaper=Sacramento Bee}}</ref>

In early 2014, New Mexico Second District Judge Nan Nash ruled that terminally ill patients have the right to aid in dying under the state constitution, i.e., making it legal for a doctor to prescribe a lethal dose of medication to a terminally ill patient.<ref>{{cite news| url=https://www.latimes.com/nation/la-na-new-mexico-aid-dying-20140120-story.html | work=Los Angeles Times | first=Saba | last=Hamedy | name-list-style = vanc | title=New Mexico judge affirms right to 'aid in dying' | date=19 January 2014}}</ref> The ultimate decision will be made with the outcome of New Mexico's Attorney General's appeal to the ruling. Organizations have been continuously pushing for the legalization of self-determination in terminally ill patients in states where the right to end one's life is prohibited.<ref>{{cite journal | vauthors = Printz C | title = Death with dignity: young patient with brain tumor puts a face on the right-to-die movement | journal = Cancer | volume = 121 | issue = 5 | pages = 641–43 | date = March 2015 | pmid = 25703858 | doi = 10.1002/cncr.29283 | doi-access = free }}</ref>

'''Medical Perspective'''

The American Medical Association (AMA) is the national association that advocates for physicians and provides guidance for the best practices for delivering health care. The AMA is responsible for maintaining the Code of Ethics, which consists of two parts: the Principles of Medical Ethics and Opinions of the AMA's Council on Ethical and Judicial Affairs.<ref>{{Cite web|title=Code of Medical Ethics: Caring for patients at the end of life|url=https://www.ama-assn.org/delivering-care/ethics/code-medical-ethics-caring-patients-end-life|access-date=2021-09-20|website=American Medical Association|language=en}}</ref> The role of physicians in patient's right to die is debated within the medical community, however, the AMA provided an opinion statement on the matter.

'''Opinion statement regarding physician-assisted suicide'''

Patients who are terminally ill or suffering from debilitating illnesses may decide that they prefer to die rather than continue suffering. Physicians commit themselves to "[[Primum non nocere|do no harm]]" and by participating in assisted suicide physicians would inherently be causing harm to their patients. Rather than participating in assisted suicide, physicians should provide palliative care to minimize patient suffering. These are recommendations for physicians from the Code of Medical Ethics Opinion 5.7<ref>{{Cite web|title=Physician-Assisted Suicide|url=https://www.ama-assn.org/delivering-care/ethics/physician-assisted-suicide|access-date=2021-09-20|website=American Medical Association|language=en}}</ref> regarding end of life care:

* Should not abandon a patient once it is determined that a cure is impossible.
* Must respect patient autonomy.
* Must provide good communication and emotional support.
* Must provide appropriate comfort care and adequate pain control.