The+Right+to+Die


 * The Right to Die: **

Should someone have a constitutional right to assisted suicide? The issue is largely controversial and immensely impactful in public policy. media type="youtube" key="ahwWlsjM_-w" width="560" height="315"

=Introduction:= toc The true question that should be asked is whether the right to assisted-suicide and/or euthanasia should be a fundamental right, guaranteed by the Constitution, or if it should be left to the individual states' policies. Euthanasia is the painless killing of a patient who suffers from some kind of irreversible illness or coma. Under the doctrine of federalism, it is timelessly noted that America is a large nation rich with diverse opinion. Allowing the Court to determine whether or not this right is constitutional is to take away from the individual state's policymaking rights. This issue is highly based on personal moral that can shift greatly from person to person and, likewise, from state to state. On the other hand, many would argue that assisted-suide and euthanasia are fundamental rights that should be given to all individuals. Considering this, the question becomes whether the court should have the extended policymaking power over euthanasia or whether individual states should be able to decide.

It is also important to note the factors impacting a court's decision to allow physician-assisted suicide, which may play a huge role in how the constitution is interpreted. These influences may include factors such as the political atmosphere, membership of the courts, and public opinions. Public opinion, specifically, tends to greatly impact the law. Currently, there is a large debate over this topic. Those in favor of medically-assisted suicide argue that it can be unethical to force a terminally-ill person to live in pain; that individuals should have a right to die with ease and dignity; and that current state legislature shows that euthanasia can be done in a fair and helpful manner. While those against the issue maintain the severe need for more research in order to determine the safety and possible effects; that the process goes against medical principals; and that assisted suicide can be extremely dangerous.

Through out the world, a handful of countries permit, to at least some extent, the practice of euthanasia (Figure 1). While some nations in Europe, such as Switzerland have relatively lenient laws regarding assisted suicide, others, such as the the Unite Kingdom, permit personal suicides, but classify assisted suicides as murders or manslaughter.



 **Figure 1.** Countries shaded in blue represent those that allow some form of assisted suicide. Each nation has established their own laws and practices around this, with Switzerland being the only nation to allow protection to foreigners in addition to Switzerland citizens. __ Within the United States, it is up to the state to decide for themselves whether they allow euthanasia to their citizens (Figure 2). Oregon was the first state to declare this right in 1994, with California allowing euthanasia last in 2015. A number of court cases have been determined in the Supreme Court and in lower courts regarding a person's right to assist someone in purposeful suicide. The famous case of //Roe v. Wade// determined that the right to privacy, guaranteed in the Fourth Amendment, extended to a woman's right to end an abortion at an appropriate stage, should she choose so. The case established in //Roe// made abortions constitutional after they were unconstitutional for long periods of time; it is also important to remember that had the composition of the court been changed even slightly, the decision could have gone the other way. The courts since then have been tasked with determining whether this right to privacy should extend to those who seek out an end to their life, but cannot do so themselves, or if allowing this goes against the government's compelling interest to protect the citizens.




 * Figure 2. ** The states shaded in blue represent those that allow some form of euthanasia, under their own guidelines. Oregon was the first state to allow this right in1994, followed by Washington, Montana, Vermont, New Mexico, and California, respectively.

= =

=Supreme Court Decisions: =

//Vacco V. Quill// (1997)
Physician-assisted suicide is illegal in the majority of states, including New York. In New York, Dr. Timothy Quill challenged the constitutionality of this policy, in hopes of allowing patients who are terminally ill or suffering immensely an option to receive a comfortable death. The New York policy made it acceptable for patients to refuse life-saving treatment options, but those who were incompetent to give a full answer could not refuse a treatment. This case was argued on the grounds of the Fourteenth Amendment. Under the Equal Protection Clause, Quill argued that it was not constitutional to allow a terminally-ill, yet competent, individual refuse treatment, while denying the right to end suffering to a terminally-ill, incompetent individual. The respondents felt that this refusal of treatment and the doctors subsequent respect to follow the patients orders was essentially the same as prescribing life ending medications without the cruelty of the patient enduring a painful death.

A unanimous decision in favor of Vacco, as written by Justice Rehnquist beginning with their opinion on the New York law, the Court stated that it did not infringe upon a fundamental right, referencing the decision in San Antonio School District v. Rodriguez, where the court stated that they must look to the Constitution for a fundamental right, rather than the to importance of a right. Because the New York law did not violate a fundamental right as established in the Constitution, the law did not violate their fundamental rights. However, the Court also hinted at the necessary requirement of a "strong presumption of validity" when analyzing New York's laws, par Heller v. Doe.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Under the rational basis test, a state law is determined to be constitutional until proven that there is no rational relationship to a legitimate state governmental interest. Furthermore, the Court expands on this by discussing the Courts long tradition of analyzing a specific persons intent when determining two act with identical consequences (in this case refusing care results in death, just as administering lethal drugs would result in the same). Therefore, the Court applied the "standard of intent" test, finding that a doctor that ends their patients life according to the wishes of the patient is a "sharp contrast" to the doctor who listens to their patient when ordered to end their life, which the Court claims is essentially killing the patient. They determined the difference was that the first doctors actions may kill the patient, while the orders to administer lethal drugs will kill the patient.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Therefore, the Court recognized that the difference in the New York law is the legality of letting someone die and the illegality of killing a patient. In conclusion, the Court completely rejected the respondents notion on the difference between assisted suicide and the refusal of treatment, stating that New York had some rational interest to enact this ban as a way of attempting to maintain the health of its citizens. And because the law allowed everyone to refuse treatment and it was illegal for anyone to partake in assisted suicide, it did not violate the Equal Protection Clause.

<span style="color: #333333; font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">//Washington V. Glucksburg// (1997)
<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Argued by Dr. Harold Glucksberg, along with four other physicians, three terminally ill patients, and the non-profit group Compassion in Dying, they challenged Washington states ban of assisted suicide. The respondents claimed that this law was illegal and liberty interest for assisted suicide was in fact protected by the Due Process Clause of the Fourteenth Amendment.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">After the District Court ruled in favor of the respondents and the subsequent reversal by the United States Court of Appeals for the Ninth Circuit, the case was argued in front of the Supreme court.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">The majority opinion, written by Chief Justice Rehnquist, reversed the Ninth Circuit Court of Appeals decision that assisted suicide was a violation of the 14th amendment. The Court stated that because assisted suicide is not a fundamental interest, it was not protected by the 14th amendment. The Court cited its decision in Moore v East Cleveland, where they determined that fundamental liberty interests that were not relevant, or "deeply rooted", in our nations past do not get protection as a fundamental right. They further analyze this by stating that assisted suicide has been frowned upon for centuries, mainly in early America due to religious beliefs and rights.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">The Court further rationalized their decision by discussing the compelling state interest of Washington to preserve the life of its citizens.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">The outcome of this case is extremely similar to the ruling in //Vacco//. Under the rationality test, the unanimous court ruled that the state statue was constitutional, as it promoted legitimate government interests.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Interestingly enough, in 2008, Washington citizens voted to approve of the Washington Death with Dignity Act. The Act outlines appropriate ways that a terminally ill, mentally stable person can in fact partake in assisted suicide. Because the decision for the legality of the state law, the new law was in fact protected by states rights, prompting a new issue of the jurisdiction for assisted suicide laws.

<span style="color: #333333; font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">//Gonzales v. Oregon//
<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Argued October 5, 2005 <span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Decided January 17, 2006

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">After Oregon voters passed Measure 16, a ballot initiative that created the Oregon Death with Dignity Act, which legalized physician-assisted suicide. Within the parameters of the law, physicians are able to prescribe a lethal dose of a predetermined medication to patients that will die within 6 months of a terminal, non-treatable condition, following an agreement by two doctors. Years later in 2001, Attorney General John Ashcroft created and issued an Interpretive Rule that physician-assisted suicide, such as the acts permissible under the Oregon Death with Dignity Act, was in fact illegal and any physician found to prescribe lethal medications would be violating the Controlled Substances Act. Shortly after, the State of Oregon, along with a number of physicians, pharmacists, and interest groups filed a challenge in the District Court of Oregon. After the District Court ruled in favor of Oregon, as well as the Ninth Circuit Court of Appeals, the case entered the Supreme Court.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">With a 6-3 decision, the Supreme Court found that the Ninth Circuit Court of Appeals was indeed correct in their ruling, yet the Court utilized a different reasoning tactic. The majority found that statue created by the U.S. Attorney General overruling state laws was not prohibited, yet affirmed the federal governments right to regulate drugs.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">While this decision did not inherently give states the right to decide whether or not they are able to enact some sort of physician-assisted suicide law, it limited the federal governments ability to stop those who have legalized assisted euthanasia.

=<span style="color: #333333; font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Judicial Interpretations =

<span style="color: #333333; font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">//Baxter v. Montana//
<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Argued: September 2, 2009 <span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Decided: December 31, 2009

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Four Montana physicians, Compassion & Choices (a non-profit that fights for patient quality improvement and access to aid in dying), and Robert Baxter, was dying of terminal lymphocytic leukemia. Fighting for a state constitutional right to have physician aid in dying, the State argued that there is no implication of a constitutional right to choose to die. After the Court ruled in favor of the plaintiffs, the Attorney General for Montana appealed the case to the states supreme court, which ruled in favor of Baxter. While the state Supreme Court found that the state constitution didn’t guarantee citizens right to assisted suicide, they also found that the constitution did not prevent it.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Unlike the cases in Washington and Oregon, this Montana Supreme Court decision did not create a euthanasia law; rather just solidified the constitutionality of physician assisted suicide should it arise later in Montana or proposed to be on ballot.

<span style="color: #333333; font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">//Morris v Brandenberg// (2015)
<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">The case begins with Aja Riggs, a New Mexican citizen who was diagnosed with advanced uterine cancer, with physicians giving here just a few weeks left to live. Her, along with physicians Katherine Morris and Aroop Mangalik fought in New Mexican court to rule that no law actually prevents doctors from performing assisted suicide. They claimed that offering a prescription for medication to end life, on the basis that the patient is terminally ill and mentally competent, is a basic human right.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">After weighing the testimonies of the patients and physicians, the New Mexican Court of Appeals determined that the New Mexico Constitution did not create the right to assisted suicide. This decision essentially reversed the district courts ruling that aid in dying is a fundamental liberty interest under the state constitution. This is a pivotal case within the issue of assisted suicide, as many states (Montana and Vermont) have recently ruled in favor of assisted suicide, stating that it is a fundamental right outlined/implied within the states constitution.

<span style="color: #333333; font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">//In re Quinlan,// 70 N.J. 10, 355 A.2d 647, 1976
<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">This was one of the first cases dealing with the issue of assisted suicide, one that each and every euthanasia case would be influenced by. It begins with Karen Ann Quinlan, who suffered cardiopulmonary arrest after subsequently ingesting a deathly combination of drugs and alcohol. This, combined with her crash diet, sent her into a persistent vegetative state. After a neurologist diagnosed her with no longer having any cognitive function, Quinlan’s parents asked that she be taken off her respirator and be allowed to die. But while Quinlan did not have any cognitive abilities, she did perform some vegetative functions, such as chewing and making sounds. Because of this, Quinlan did not meet “Harvard’s Criteria” in order to be called brain dead, therefore her doctor refused to “pull the plug”.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Her father then appealed the case to the Supreme Court of New Jersey, requesting to have her life support removed, claiming that he was protected under the U.S. Constitutions first amendments freedom of religion clause. After the Court rejected his request, they fought the holding under the Eighth Amendment’s protection of cruel and unusual punishment, claiming that keeping Quinlan alive was cruel. The Court found that it was not cruel due to the fact that it was an accident of “fate and nature”.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">The State Supreme Court did think that an individual’s right to privacy was in fact relevant in the case, claiming that while the U.S. Constitution doesn’t explicitly indicate a citizens right to privacy, other Supreme Court cases have implicitly implied that all citizens have this right. Because of pivotal cases, such as//Griswold v. Connecticut// and //Roe v. Wade//, the Court ruled that “Karen’s right of privacy may be asserted on her behalf by her guardian under the peculiar circumstances here present”.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">The Court’s also discussed New Jersey’s interest in preserving life. After discussing previous cases where the court ordered medical treatment be continued, they were all in circumstances where there was “minimal bodily invasion”. However, in Quinlan’s case, she required 24-hour service and care, quite the opposite of minimal bodily invasion.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">The Court also addressed the issue of doctors refusing to partake in assisted suicide due to moral or certain medical standards. The Courts suggested that all hospitals form some sort of ethics committee to decide on morally difficult cases, as to stop one physician from determining a patents fate.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Before the Court hearings, New Jersey stated that they would prosecute anyone who terminated Quinlan’s life claiming that this consisted homicide. The Supreme Court overturned this, however, stating that “the exercise of a constitutional right, such as we have here found, is protected from criminal prosecution, with the constitutional protection extending to third parties whose action is necessary to effectuate the exercise of that right”.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Therefore, in conclusion, the Supreme Court ruled that her respirator could be removed, following an approval from the hospitals ethics committee. They also claimed that all parties involved would be legally immune from criminal and civil prosecution. While her respirator was removed following the Court’s decision, she continued to live until 1985, breathing on her own, until her death as a result of multiple infections. = = =The Constitutionality of the Right to Die=

The constitutional debate revolving around the right to die has largely been based around the due process clause of the fourth and fifteenth amendment. According to the textbook Constitutional Law for a Changing America, “the fifth amendment states that congress shall not deprive any person of “life,liberty, or property, without due process of law”, and the fourteenth amendment uses the same wording to apply to the states.” Traditionally the due process clause was meant to insure American citizens received a fair trial, but the supreme court has interpreted the two clauses together to create the doctrine of substantive due process. The substantive clause had largely been used to prevent government intervention into business, but that all changed in the 1961 Supreme Court Case Poe V Ulman. The case sought to strike down a Connecticut law prohibiting the use of birth control, even by married couples. “To Justice Harlan due process represented “a rational continuum which, broadly speaking, includes a freedom from all substantial arbitrary impositions and purposeless restraints”. In his dissent he rejected the idea that due process only applied to fair trial procedures and only protected the first eight amendments. Harlan rejected the law in Poe, because he felt it used criminal law to infringe on “intimate details of the marital relation”. It was not until Griswold V. Connecticut that Harlan’s dissent was used to establish the right to privacy. This new interpretation of the 5th and 14th amendments paved the way for such ground breaking supreme court cases as Stanley V Georgia (1969) and Lawrence V Texas (2003). In both cases the court ruled that as Americans, we have the right to determine what we do behind closed doors, in other words Americans have the right to privacy.



The right to privacy, as guaranteed by the constitution, has since been used to justify a number of rights considered to be fundamental, but not enumerated in the amendments. Many consider this to be controversial, because it essentially allows the judiciary branch to act as legislator. Despite its controversy, the right to privacy has been vital to the right to die debate. Starting in the 1970’s, states started using the right to privacy to justify what it called substituted judgements. Substituted judgements can best be understood from the judgement handed down in the New Jersey Supreme Court case In re Quinlan (1976). “The supreme court decided that the right to privacy is broad enough to allow a patient to decline medical treatment under certain circumstances. Because Karen could not make that decision for herself, the “only practical way to precent the destruction of the right to privacy is to permit Karen to render their best judgement as to whether she would exercise it in these circumstances.

Not all states signed on to this judgement, as the Missouri Supreme Court ruled that families must present “clear and convincing” evidence of the patients intent. According to the Journal of Legal Medicine, “in Cruzan, the United States Supreme Court noted that the Missouri Supreme Court had properly established a heightened evidentiary burden as a means of protecting the states interest in life.” Essentially the supreme court determined that if a state can produce clear and convincing evidence that the law is for the furtherance of the government interest, then it will be constitutionally acceptable. The finding in this case made the right to die a purely state matter, which highlights the federalist system we have in the United States of America. Generally speaking, congress can only pass law that are necessary and proper for upholding the enumerated rights. In other words, the federal government can only pass laws that are specifically listed in Article 1, Section 8 of the constitution.

The right to die has largely been shaped by both the states desire to protect its citizens and the right to privacy, as guaranteed by substantive due process. Given that the right to die is not an enumerated right guaranteed by the constitution, the right is largely a state matter. To inhibit on the right to die, states must prove that their is a clear and convincing evidence that the law furthers a government interest. According to the New York Times, “the ruling spurred enormous interest in living wills and other advance directives that allow people to spell out, in advance, what treatment they want, and who should make decisions from them if they become incapacitated”. The ruling also paved the way for a new piece of legislation, titled The Patient Self-Determination Act, which requires all hospitals that receive medicaid or medicare funding to advise patients on their states policies for the right to die. According to the New York Law School Law Review Journal, “Today, every state has a law relating to advance directives, and mist states have laws providing for a combination of living wills and durable powers of attorney or health care proxies—the essential legal tools that allow patients to exercise their end-of-life choices even after they lose competence”. Cruzan had a significant effect on the right to die debate. While the rulings in Vacco and Washington overturned the fundamental right to die, “few noticed at the time, however, that critical concurring justices viewed the cases as raising only facial challenges to laws against assisting suicide and reserved the right to consider in later cases whether those laws are unconstitutional as applied to terminally ill adults who wish to die”. While it was a small victory for those the oppose the right to die, the rulings by no means ended the debate on the right to die. The decision to pass laws on the right to die is a state matter, and so the state legislation put in place is largely a reflection of its constituents ideology and view points.

=Influences= <span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">There are four key areas of influence to investigating the right to die: ideological influences, legal influences, political influences and societal influences.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">Ideologically speaking, the right to die is a moral principle based on the fundamental belief that humans are entitled to having the ability to take their own life by committing suicide or undergoing voluntary euthanasia. These instances are usually related to cases of the terminally ill, however, if we look at euthanasia laws in other countries, like the ones in Belgium (see political influences), we find this isn't always the case. On the very basic level, what would be considered permissible with the affirmation of the right to die is suicide, assisted-suicide, or the declining of life-prolonging treatment. The ideological sphere of this issue presents us with multiple philosophical questions to help us understand the different perspectives, while trying to help direct the individual on judging the issue properly. First we must begin by asking who, if anyone, should be empowered to make these decisions? This asks whether or not it is the right of the state to dictate this controversy or if it is only a matter for the individual. Also, considering the many different real-world applications of this issue, we see a wide range of political stances, and we must ask ourselves where should the line be drawn? We see that conflict arises with the government's legitimate state interest in preventing irrational suicides and where the government should interfere and where they shouldn't. It is important to consider these ideological dilemmas when we investigate the other fields of influence. <span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">From a legal perspective, the right to physician-assisted suicide is not considered a fundamental right in the United States; therefore, should the Supreme Court choose to hear a case regarding this, a minimal amount of Judicial Scrutiny would be applied under the rational-basis test. Thus, states have the right to create their own policy around this issue, and it will likely be upheld in court room.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">In terms of political influences, it is important to fully consider the United Stats' political action, while also exploring other political opinions in other countries. We find that the United States has a fairly open policy, allowing states to determine their stance on the issue, without asserting any official federal influence. Luxembourg, the Netherlands, Switzerland, and Canada are examples of countries that have federally supported the right to die through assisted-suicide and euthanasia. The Supreme Court of Canada recently decided denying the right to die is fundamentally unconstitutional. Belgium also has an interesting policy when it comes to the right to die. In Belgium, the right to die is permissible to the fullest possible extent. Not only is euthanasia permissible for the terminally ill, but we see the legal assertion for the individual right to suicide for any reason. The country's policy allows for the professional medical assistance of a doctor and euthanasia medication for individuals without any medical issues at all. The country supports the depressed, and individuals lacking the drive to live in their right to commit suicide. Relating back to the first section, inspecting the ideological influences, we must ask when comparing the different state policies, where the line morally should be drawn, if at all. Should there be a lack of restrictions on individual state policy, like in the United States, should there be mildly asserted right to die legislation for just the terminally-ill, or should there be no restrictions at all, allowing any person, without any specific reason, to commit suicide as enacted in Belgium? Due to the wide range of political action, we find that there really is lack of political uniformity on this topic.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">The societal impacts involving this public policy are also prominent, for physician-assisted suicide is thought to be more liberal than conservative. However, it appears that even conservative-republicans see the potential for a positive impact of allowing physicians to offer and assist terminally-ill, adult patients in suicide if they choose to do so. The following video demonstrates this opinion:

media type="youtube" key="RxzmKNkALxE" width="560" height="315"

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">The story of Brittany Maynard choosing to end her own life, after battling terminal cancer, has given momentum and empathy to the side in favor of physician-assisted suicide. The nonprofit organization [|Compassion & Choices]has been leading movements toward allowing comfortable deaths to terminally-ill or terminally-injured individuals by initiatives to make death a legitimate, supported option, and promoting laws that allow patients full access to death as a treatment option. From this standpoint, Compassion & Choices focuses more on changing state statues and voter perspectives than attempting to make the right to die a fundamental, constitutionally recognized right.

<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">On the other hand, there is also strong support against the practice of euthanasia. For example, several prominent nonprofit disability organizations have outwardly opposed the legalization of this practice, including [|Justice For All] (JFA), Disability Rights Education and Defense Fund (DREDF), and [|Not Dead Yet] (NDY). The organization Not Dead Yet promotes better information to ensure that the refusal/withdraw of life-sustaining treatment is entirely voluntary, and opposes laws that would make physician-assisted suicide legal.

=<span style="font-family: 'Helvetica Neue',Helvetica,Arial,sans-serif;">References =

"Karen Ann Quinlan." //Wikipedia//. N.p., n.d. Web. 1 Dec. 2015. <https://en.wikipedia.org/wiki/

Karen_Ann_Quinlan#/media/File:KarenAnnQuinlan.jpg>.

"Lawrence V Texas." //Wikipedia//. N.p., n.d. Web. 1 Dec. 2015. <https://en.wikipedia.org/wiki/

Lawrence_v._Texas>.

"Nancy Cruzan." //Youtube//. N.p., n.d. Web. 1 Dec. 2015. <https://i.ytimg.com/vi/mZO2te-sv3g/

maxresdefault.jpg>.

Sawicki, Nadia N. "FREEDOM OF CHOICE AT THE END OF LIFE: PATIENTS' RIGHTS IN A SHIFTING LEGAL AND

POLITICAL LANDSCAPE: A New Life for Wrongful Living." //New York Law School Review//: n. pag.

Print.

Epstein, Lee, and Thomas Walker. //Constitutional Law for a Changing America: Rights, Liberties, and//

//Justice//. Eighth ed. London: Sage, n.d. Print.

Lewin, Tamar. "Nancy Cruzan Dies, Outlived by a Debate Over the Right to Die." //New York Times// [New

York] 27 Dec. 1990: n. pag. Print.