The Legality Of Euthanasia In Today’s Society Essay Example for Free

The Legality Of Euthanasia In Today’s Society Essay Introduction This work focuses on the legality of euthanasia in today’s society. In the sequel various case laws have been discussed. In several countries terminally ill patients are clamouring for euthanasia in order to put a stop to their torment. There is however a great difficulty involved in obtaining death. The doctors and the courts are not taking cognizance of patients’ requests for euthanasia, but are deciding on their own as to which patient should be killed and when such a patient should be killed. This death is generally by means of withdrawing life support systems. There have been several demands for legalizing voluntary euthanasia and physician assisted suicide. Such demands have occurred all over the world. However, the European Court of Justice decided in the year 2002, that no EU Citizen had the right to die. Similarly, the US Supreme Court opined that no US Citizen had the right to die. This has resulted in individual countries having to deal with this problem on their own and a certain measure of acceptance is evident in the Netherlands, Japan, Oregon and Columbia. In general, two arguments are put forward in support of euthanasia and physician assisted suicide, namely, the mitigation of the intolerable pain and discomfort caused by terminal illness; and to enhance individual freedom. These two factors are taken into consideration by the government in order to legalize euthanasia, for example, in the Netherlands, where suffering has to be accompanied by a recurring request for mercy killing. Euthanasia is the process of bringing about an easy death. It refers to acts, which terminate or shorten life painlessly in order to end suffering where there is no prospect of a cure. There are only two choices available to patients with fatal illness, either a slow death involving unrelieved suffering or euthanasia. Terminally ill patients suffer from depression or a false sense of unimportance, which tends to affect their judgment. Their decision-making may also be influenced by confusion or dementia, which could be lessened with suitable treatment. It is very important to remember that, patients who on admission say let me die usually after effective relief from symptoms are most grateful that their request was not acceded to. Terminally ill patients are also adjustable to a high level of disability as they value what little quality of life they have left. The legal position in respect of selective non-treatment was dealt with by the House of Lords in Airedale NHS Trust v Bland[1], in which the applicant, a health authority sought an order to withdraw life-sustaining treatment and provide medical treatment that would enable a peaceful and dignified death with the minimum of pain. The family of the patient supported this application. The respondent, 21-year-old Anthony Bland, had been in a persistently vegetative state for more than three years and though not brain dead, he had no cognitive function. The unanimous judgment of all the doctors who examined him was that there was no hope of a cure. Under these circumstances, it was thought suitable to stop further treatment. The judge granted this order, which was confirmed by both the Court of Appeals and the House of Lords. The latter held that a doctor, who has to care for a patient who is unable to indicate his willingness to be treated, need not extend the patients life regardless of the quality thereof. In F v West Berkshire Health Authority[2] the Court held that medical treatment and artificial feeding, could be discontinued if the patients best interests were served. To determine what course of action would further the best interests of the patient, the court used the test laid down in Bolam v Friern Hospital Management Committee[3], which required the acquiescence of a large, informed and responsible group of medical practitioners. As the termination of life-supporting treatment in this case was in accordance with the criteria set out in a discussion paper by the British Medical Association[4], these â€Å"criteria [were] a) Rehabilitative efforts for at least 6 months after the injury; b) the diagnosis of irreversible PVS should only be considered confirmed after 12 months; c) the diagnosis should be confirmed by two other independent doctors; d) the wishes of the family should be respected[5].† The court found that there had been compliance with the Bolam requirement. In this case Lord Mustill highlighted the need for legislation relating to euthanasia stating that, â€Å"The whole matter cries out for exploration in depth by Parliament and then for the establishment by legislation not only of a new set of ethically and intellectually consistent rules, distinct from the general criminal law, but also of a sound procedural framework within which the rules can be applied to individual cases[6].† In R (Pretty) v. Director of Public Prosecutions[7], Lord Steyn restated that change of the law on assisted suicide should be carried out by the legislature rather than by judges.  Ã‚   Case law demonstrates the paradox that results from the current law.   As Dame Butler-Sloss P. emphasised in B v An NHS Hospital Trust[8], a competent patient may refuse any form of medical treatment, even life-prolonging medical treatment, for whatever reason.   B was able to insist that the ventilator, which kept her alive, was to be disconnected. Nevertheless, Diane Pretty who was able to make a competent and autonomous choice about the timing and manner of her death, was unable to apply this decision due to a ban on assisted suicide and consequently died in a way that she had tried to avoid. Moreover, Bland, was unable to make any choice, therefore his existence was held to justify the withdrawal of artificial feeding resulting in his death. In Re J (a minor)[9] J, an infant had serious brain damage and large areas of his brain were filled with fluid instead of tissue. This resulted in convulsions and stoppage of breathing. He had been placed on a ventilator twice and it was certain that he would develop spastic quadriplegia. Speech would be denied to him for ever and his life span was considered to be very short. In respect of his being linked to a ventilator in the future, two medical practitioners certified that it would not be in Js interest to be ventilated again. Accordingly, the court issued an order in agreement with these medical experts. An argument was raised against this court order, but the Court of Appeal rejected it and observed that the court could not issue a life-ending order unless it was absolutely certain that the quality of the childs subsequent life would be intolerable to the child and demonstrably so awful that in effect the child must be condemned to die. Both AVE or active voluntary euthanasia and PAS or physician assisted suicide do take place. The Assisted Dying for the Terminally Ill Bill[10], which permits doctors to resort to AVE under strictly limited circumstances, was recently introduced in the House of Lords. The extant Case law confirms that the best interest model of decision-making is concerned not only with the physical well-being of the patient, but also the psychological, moral, ethical and social interests. By implication, the non – transparent nature of the best interests test implies that it is vulnerable to exploitation. First, there is a danger that the values of the decision-maker may prevail over those of the patient leading to paternalistic decisions.   Second, references to the wider interests of the patient could bring about a masked development of third party interests. Moreover, this approach opposes the spirit of the Mental Capacity Act 2005[11], which emphasizes the promotion of self-determination for adults who lack capacity. It permits anticipatory treatment decisions to be made before the patient becomes incapacitated and it allows proxy decision-makers to decide on behalf of incapacitated patients. Causing a patients death by means of a lethal injection differs from causing the death of a patient by refusing to provide treatment. The same line of pro-euthanasia argument is also constructed through a confusion of means and ends. This argument states that when death is the inevitable outcome, the means used to achieve such death, whether by withdrawing life support systems or by administering a lethal injection, are morally irrelevant and should therefore be legally irrelevant[12]. This argument is unacceptable and the means that bring abut a person’s death should necessarily matter not only morally but also legally. It is essential to understand that the issue is not one of dying but rather of how a person dies. The moral intuition of any person states that there are essential differences between letting nature take its course, which also includes the withdrawal of life-support systems and treatment, and the outright killing of a dying person. Advocates of euthanasia contend that that the manner in which a person dies should be a private matter, whereas those who are opposed to legalizing euthanasia state that such arguments are fallacious. These opponents of euthanasia strongly subscribe to the view that every persons death necessarily involves others, including healthcare professionals and that it also includes values of society and symbols. Furthermore, wherever euthanasia takes place, the manner in which death occurs will not be restricted to the patient’s self-determination and personal beliefs because of the fact that euthanasia is an act that requires two people to make it possible and a complicit society to make it acceptable[13]. The very concept of legalization of physician assisted death has been subjected to a great deal of debate with regard to its benefits and disadvantages. These debates had been totally based on theory and hypothesis. In this context in the year 1977, the Supreme Court of the USA addressed this subject and stated that â€Å"perhaps we should wait [on the question of legalization] until we know more.† [14] In the written evidence submitted by Professor Margaret, she stated that at present there was five years of empirical knowledge in respect of the effects that the legalization of euthanasia had produced in the state of Oregon. Furthermore, there was available an even more detailed amount of empirical data from the Netherlands covering a sixteen year period in respect of euthanasia. She contended that these data sets clearly support the claim that the legal process can be controlled effectively, with the result that abuse of euthanasia does not occur and if at all it does take place, such instances are very infrequent. In the state of Oregon no incident of substantive abuse of euthanasia had been reported and the incidents reported in the Netherlands are practically none. The Legislation in respect of euthanasia is closely related to essential and crucial enhancements in palliative and hospice care[15]. The act of committing suicide has been considered to be possible only for a person endowed with a considerable amount of courage, but the relevant scientific literature considers such an act to be the act of a mentally imbalanced person. Moreover, it considers suicide to be an act of self destruction by a person who lacks lucid thinking and who is a lunatic. Similarly patients who request physician assisted death are usually those who have been suffering from either severe depression or psychological imbalances[16]. The Assisted Dying for the Terminally Ill Bill was introduced in order to legalize, in respect of people who are terminally ill, who are mentally capable and whose suffering is unbearable, medically assisted death or, in instances where the patients are physically incapable of carrying out the concluding deed that would end their life, voluntary euthanasia in order to end their life. A scrutiny was made of the principle on which the Bill was to be based as well as the practical outcome of the bill if it were to become law. Subsequently the experiences of countries that had formulated legislation to permit euthanasia were examined in depth and then an analysis was performed in respect of public opinion in the United Kingdom with regard to euthanasia. The principle of personal autonomy constitutes the basis for this Bill. The supporters of this bill strongly contend that people who are terminally ill should be given the right, conditioned by appropriate safeguards, to obtain medical assistance in order to die in the same manner that patients, whether terminally ill or otherwise, are permitted by right to decline life-prolonging treatment. However, opponents of this bill are of the opinion that these two situations cannot be compared and that ensuring safeguards would not be feasible and that intentional killing, regardless of the reason, should not be permitted. These opponents strongly resist any change to the law in this context[17]. Further, their Lordships held that at the practical level there were opposing views regarding the possible effects of the Bill in providing help to some people or in causing harm to others. In this matter the General Medical Council communicated to their Lordships that â€Å"a change in the law to allow physician-assisted dying would have profound implications for the role and responsibilities of doctors and their relationships with patients†[18]. This bill grants immunity to medical staff members, who comply with its terms, from prosecution for breach of professional oath or affirmation. Moreover this bill makes it possible for the terminally-ill patients to obtain such pain-relief as they require in order to alleviate the symptoms of their illness[19].   Unfortunately, this bill was defeated in the House of Lords[20]. Several examples can be cited of persons who have pleaded for euthanasia to be permitted in respect of their near and dear ones. One such instance is that of Bill Starr, whose wife Maureen – Anne was suffering from Kirkby Alzheimer’s disease.   Bill wanted his wife to be put out of her misery by resorting to euthanasia. This was due to the fact that his wife Maureen-Anne had drastically worsened in her health, which was a cause of anguish for both of them. Bill wanted his wife to die with dignity. He also stated that â€Å"If this was an animal you would be able to put it out of its misery and the same should apply to humans. Her brain is shrinking and it is just downhill all the way from now. There needs to be a change in the law to allow euthanasia to go ahead for all those who need it[21]. Madeleine Zeffa Biver’s son asked the court to prosecute those who had helped her to commit suicide in Spain. Madeleine had written to the El Pais newspaper in which she expressed her desire to die with dignity. She stated that â€Å"Please give me a glass of water, wine or whiskey†¦I want to die with my head held high†¦This is not a crime. It is not a murder.† Despite assisting suicide being a crime in Spain, The Right to a Dignified Death group asked some of its members to be present while she died and contended that â€Å"there was nothing criminal about offering moral support to someone who wished to kill themselves[22].† Eighty percent of the people in the United Kingdom are of the opinion that the law should respect the wishes of terminally ill patients in pain and permit a doctor to end their life. In the UK it has been observed that under certain circumstances, euthanasia is acceptable to the public. This has been the finding of the British Social Attitudes Survey. Research conducted for the survey indicates that backing for voluntary euthanasia depends strongly on whether someone is terminally ill, on levels of suffering and on how death occurs. There is much greater support for a doctor being permitted to end someones life rather than a relative doing so, or for suicide assisted by a doctor. However, public support for euthanasia is lacking or is negligible in cases where an individual does not face death as a result of their condition. This survey was conducted after the previous year’s attempt to change the law failed. The conclusion reached by the Survey was that The disjuncture between the current law on assisted dying and majority public opinion thus seems unlikely to simply disappear. Pressure to mount further attempts to change the law in some ways at least looks set to continue[23]. When a physician induces easy death to terminally ill patients by administering lethal drugs, then such a process is known as Euthanasia. Physician assisted suicide takes place when a doctor intentionally helps a person to commit suicide by providing such a patient with drugs for self-administration, at that person’s voluntary and competent request. This act puts an end to or shortens the life span of patients who suffer from incurable diseases. Patients with terminal illness can either undergo a slow and ghastly death with unbearably sufferings or they can die with dignity and without pain by resorting to euthanasia. It becomes a permissible option when comfort care ceases to be effective for the terminally or incurably ill[24]. The term comfort care refers to palliative and supportive treatment used in hospice programs and elsewhere. This comfort care has to be made the standard medical treatment for patients who have rejected therapeutic or life-sustaining treatment or who are suffering from a terminal illness. Comfort care relieves symptoms, improves the quality and meaning of the patient’s remaining life and eases the process of dying. Physician assisted death becomes a legitimate option only as a treatment of last resort and after customary procedures for comfort care have been found substandard by competent patients in the context of their own situation and values[25]. In the cases of Vacco v Quill and Washington v Glucksberg, the U.S. Supreme Court ruled that the constitution had not granted any right to physician-assisted suicide; its decision clearly approved the use of intensive palliative care and seemed to permit experimentation at the state level so that this â€Å"earnest and profound debate† could continue[26]. The injury suffered by actor Christopher Reeve[27] and his response to his condition has been the subject of numerous news stories. The public sees a man who previously enjoyed a physically active lifestyle, but who now relies on a respirator to breathe, and on other people to provide for his every physical need. Rick Hansen[28] and Teny Fox[29] are examples of people who have not only contributed to the society in significant ways, but who have also captured the imagination of the public in their courageous journeys to help others suffering from spinal cord injuries and cancer respectively. The actions of Dr. Jack Kevorkian[30], a doctor dedicated to aiding the terminally ill in their chase for death, repeatedly places this issue about the value of life before the public and the courts in the United States. Flach[31] defines mental health in terms of resilience. He proposes that when we experience disturbance in our lives, it is through resilience that we are able to move through our experiences in good mental health. He argues that it is how well we are able to integrate each new experience and circumstance into our lives that leads to successful adaptation throughout our lives. In her book, Resilient Adults: Overcoming a Cruel Past, Gina O’ Connell Higgins[32] examines the lives of forty individuals who have suffered cruelty and abuse in their childhood, but who have led purposeful, successful adult lives. O’ Connell Higgins identifies attachment to a parental surrogate as an important factor in the development of self-esteem in the subjects she studies. Research on resilience had shown that resilience is significant in the lives of many individuals suffering extreme trauma from abuse and other circumstances it will also contribute to the well being of an individual facing physical pain or disability. Certain other behaviors and attitudes also contribute to positive adjustment to chronic pain. Kelly and Clifford[33] studied the impact of narrative group therapy on subjects with the chronic pain of Fibromyalgia. They found that this therapy allowed the subjects â€Å"the opportunity to re-examine and restory [sic] their lives, to not get stuck in repeating the story of helplessness, and to harness their own resources† (p. 276). It is an established fact that people are able to assess the possible threat in the event of any crisis and they can balance their ability to cope with the crisis or event based on their analysis of the amount of threat involved[34]. At this juncture, a relationship between coping up with helplessness and increase in the degree of disability in chronic pain patients was found by Lenhart and Ashby[35]. Byrant[36] has propounded a four-factor model of perceived control that avoids negative events, tackles negative events, strives to achiever positive outcomes and values positive events. His theory is that not only the terrible illness or disability but also the patients’ perception of their ability to cope that has great importance. Other forms of interventions have been found helpful for people coping with diseases including cancer. Researchers reported that Interpersonal Therapy techniques focusing on interpersonal relationships, role transitions, and grief reactions were beneficial for such patients[37]. Julia Faucett[38] studied the effects of chronic pain on social supports, family relationships and incidences of depression. Her study showed that the negative response of family and friends to the patient’s pain significantly contributed to depression. Although euthanasia proponents argue that pain validates the right for Physician-assisted suicide, research suggests that the link between the desire for suicide and pain is much more complicated than a one to one correlation. This link between depression and suicidal ideation is commonly found in cancer patients[39]. It not chronic pain, in isolation, that leads to a desire for Physician Assisted Suicide. This process is determined by social, familial and personal issues and several studies have revealed that â€Å"the measurement tools intended to determine the symptoms for cancer patients, and their entire family, should be so developed as to help caregivers to attend to the needs of cancer patients and their families during the course of the illness[40].† Fife[41] found that the meaning individuals give to having cancer affected how they dealt with the disease in their lives. She found that the more social support patients perceived they have had from family, fiends, and medical professionals the more positive meanings the patients had regarding the impact of the illness on their lives. In Aronsons study of quality of life in persons with multiple sclerosis and their caregivers, she concludes that Determining those elements that have an impact upon an individuals quality of life may help inform decision-making in the planning of interventions, treatments, and services aimed at enhancing quality of life[42]. Conclusion Physician assisted death is a one time process and it should be made available to the patients suffering from terminal illnesses to reduce their suffering and permit them to exercise their rights to self-determination. Chances of indiscriminate usage of this device are high. To encounter this problem a proper and meticulously designed mechanism has to be implemented to avoid abuse of this provision. It is therefore essential to legalize physician-assisted death, but with sufficient protections to shield susceptible patients[43]. Societal opinion regarding the morality of suicide has been ambiguous since historical times. In the early Roman and Greek civilizations, suicide was of frequent occurrence. With the development of Christianity, suicide was deemed to be a sin. However, in other cultures, suicide was accorded the status of honourable death. Hara-kiri was a private ceremonial form of suicide resorted to by the Japanese in order to safeguard their honour. In the Netherlands, physician assisted suicide is permitted by law. In the Netherlands legislation was passed in 1993, which exempted physicians from prosecution if they had assisted in suicide, provided they had adhered to the procedures prescribed by the law[44]. Bibliography    Alter, C.L., Fleishman, S.B., Kornblith, A.B., Holland, J.C., Biano, D., Levenson, R., Vinciguerra, V., Rai, K.R. (1996). Supportive telephone intervention for patients receiving chemotherapy. Psychosomatics, 37, 425-431. Aronson, Kristan J. (1997). Quality of life among persons with multiple sclerosis and their caregivers. Neurology, 48, 74-80.    Assisted Dying for the Terminally Ill Act 2005. Parliamentary copyright House of Lords 2005. HL Bill 3654/1. Airedale NHS Trust v Bland. (1993) 1 ALL ER 821 (CA). Bolam v Friern Hospital Management Committee (1957) 2 ALL ER 118; (1957) 1 ELR 582. Burt RA. 1997, The Supreme Court speaks-not assisted suicide but a constitutional right to palliative care. N Engl J Med.; 337: 1234-6. B v An NHS Hospital Trust (2002) 2 All ER 449. Byrant, Fred B. (1989). A four-factor model of perceived control: avoiding, coping, obtaining, and savoring. Journal of Personality, 57, 773-797. Callahan D. When self-determination runs amok. Hastings Center Report 1992; 22(2): 52-55. Davey, G.C.L. (1993). A comparison of three cognitive appraisal strategies: the role of threat devaluation in problem-focused coping. Personality and Individual Differences. 14, 535-546. Faucett, Julia A. (1994). Depression in painful chronic disorders: the role of pain and conflict about pain. Journal of Pain and Symptom Management, 520-526. Fife, Betsy L. (1995). The measurement of meaning in illness. Social Science Medicine, 40, 1021-1028. Flach, Frederic. (1988) Resilience: Discovering a New Strength at Times of Stress. New York, New York, New York: Fawcett Columbine. F v West Berkshire Health Authority. (1989) 2 ALL ER 545; (1990) 2 AC 1. Hansen, Rick Taylor, Jim. (1987). Rick Hansen: Man in Motion. Vancouver: Douglas McIntyre. House of Lords: Assisted Dying for the Terminally Ill Bill [HL] Volume I: Report Ordered to be printed 3 March 2005 and published 4 April 2005 Published by the Authority of the House of Lords Husbands euthanasia plea. January 4, 2007. Ashfield Observer.  © 2007 Johnston Publishing Limited. Document ASHFOB0020070105e31400004. Retrieved from http://global.factiva.com/ha/default.aspx Kelly, Patricia and Clifford, Patrick. (1997). Coping with chronic pain: assessing narrative approaches. Social Work, 42, 266-277. Kiser, Jerry D. January 1996. Counselors and the Legalization of Physician – Assisted Suicide. Counseling and Values. v 40. n2 ISSN: 01607960. p. 127-31. Lenhart, R.S., and Ashby, J.S. (1996). Cognitive coping strategies and coping modes in relation to chronic pain disability. Journal of Applied Rehabilitation counseling. 27, 15-18. Massie, M.J., Gagnon, P., Holland, J. (1994). Depression and suicide in patients with cancer. Journal of Pain and Symptom Management, 9, 325-340. Mental Capacity Act 2005, ISBN 0  10  540905  7. O’ Connell Higgins, Gina. (1994). Resilient Adults: Overcoming a Cruel Past. San Francisco Ca: Jossey-Bass Publishers. Pfeifer, J.E., Brigham, J.C. Robinson, T. (1996). Euthanasia on trial: examining public attitudes toward nonphysician-assisted death. Journal of Social Issues, 52, 119-129. Quill TE, 1993. Death and dignity. New York: W.W. Norton. R (Pretty) v. Director of Public Prosecutions (2002) UKHRR 97, (2002) 35 EHRR 1, (2002) 2 FLR 45. Re J (a minor) (1990) 3 ALL ER 930. Reeve, Christopher. (1998). Still Me. New York: Random House Publishing. Regulating Physician-Assisted Death, 1994, retrieved 25 January 2007 from https://content.nejm.org/cgi/content/full/331/2/119. Scrivener, Leslie. (1981). Terry Fox: His Story. Toronto: McClelland Stewart.    The Assisted Dying for Terminally Ill Bill 2005. The National Council for Palliative Care. Retrieved from http://www.ncpc.org.uk/ethics/assisted_dying.html Tremlett, Giles. Euthanasia row: The colourful life and controversial death of Jacques Brels muse: Judge investigates sons claim Madeleine was helped to kill herself. January 19, 2007. Madrid. The Guardian  © Copyright 2007. Vachon, Mary, Kristjanson, Linda, Higginson, Irene (1995). Psychosocial issues in palliative care: the patient, the family, and the process and outcome of care. Journal of Pain and Symptom Management, 10, 142-150. Ward, Lucy and Carvel, John. Euthanasia: Four out of five want to give doctors right to end life of terminally ill patients in pain. January 4, 2007. The Guardian  © Copyright 2007. Written Evidence, Memorandum by Professor Margaret Battin of Utah University, USA, House of Lords, Select Committee on the Assisted Dying for the Terminally Ill Bill, Volume III: Evidence – Individual Submissions. [1] Airedale NHS Trust v Bland. (1993) 1 ALL ER 821 (CA). [2] F v West Berkshire Health Authority. (1989) 2 ALL ER 545; (1990) 2 AC 1. [3]Bolam v Friern Hospital Management Committee (1957) 2 ALL ER 118; (1957) 1 ELR 582. [4] British Medical Association Treatment of Patients in persistent Vegitative State. [5] Ibid. [6]Bolam v Friern Hospital Management Committee (1957) 2 ALL ER 118; (1957) 1 ELR 582. [7]R (Pretty) v. Director of Public Prosecutions (2002) UKHRR 97, (2002) 35 EHRR 1, (2002) 2 FLR 45. [8] B v An NHS Hospital Trust (2002) 2 All ER 449. [9] Re J (a minor) (1990) 3 ALL ER 930. [10] Assisted Dying for the Terminally Ill Act 2005. Parliamentary copyright House of Lords 2005. HL Bill 36   Ã‚   54/1. [11] Mental Capacity Act 2005, ISBN 0  10  540905  7. [12] Callahan D. When self-determination runs amok. Hastings Center Report 1992; 22(2): 52-55. [13] Ibid. [14] Written Evidence, Memorandum by Professor Margaret Battin of Utah University, USA, House of Lords, Select Committee on the Assisted Dying for the Terminally Ill Bill, Volume III: Evidence – Individual Submissions. [15] Ibid. [16] Written Evidence, Memorandum by Professor Margaret Battin of Utah University, USA, House of Lords, Select Committee on the Assisted Dying for the Terminally Ill Bill, Volume III: Evidence – Individual Submissions. [17] House of Lords: Assisted Dying for the Terminally Ill Bill [HL] Volume I: Report Ordered to be printed 3 March 2005 and published 4 April 2005 Published by the Authority of the House of Lords London [18] House of Lords: Assisted Dying for the Terminally Ill Bill [HL] Volume I: Report Ordered to be printed 3 March 2005 and published 4 April 2005 Published by the Authority of the House of Lords London [19] Ibid. [20] The Assisted Dying for Terminally Ill Bill 2005. The National Council for Palliative Care. Retrieved from http://www.ncpc.org.uk/ethics/assisted_dying.html [21] Husbands euthanasia plea. January 4, 2007. Ashfield Observer.  © 2007 Johnston Publishing Limited. Document ASHFOB0020070105e31400004. Retrieved from http://global.factiva.com/ha/default.aspx [22] Tremlett, Giles. Euthanasia row: The colourful life and controversial death of Jacques Brels muse: Judge investigates sons claim Madeleine was helped to kill herself. January 19, 2007.   Madrid. The Guardian P. 23.  © Copyright 2007. The Guardian. [23] Ward, Lucy and Carvel, John. Euthanasia: Four out of five want to give doctors right to end life of terminally ill patients in pain. January 4, 2007. The Guardian 9.  © Copyright 2007. [24] Quill TE, 1993. Death and dignity. New York: W.W. Norton. [25] Ibid. [26] Burt RA. 1997, The Supreme Court speaks-not assisted suicide but a constitutional right to palliative care. N Engl J Med.; 337: 1234-6. [27] Reeve, Christopher. (1998). Still Me. New York: Random House Publishing. [28] Hansen, Rick Taylor, Jim. (1987). Rick Hansen: Man in Motion. Vancouver: Douglas McIntyre. [29] Scrivener, Leslie. (1981). Terry Fox: His Story. Toronto: McClelland Stewart. [30] Pfeifer, J.E., Brigham, J.C. Robinson, T. (1996).   Euthanasia on trial: examining public attitudes toward nonphysician-assisted death. Journal of Social Issues, 52, 119-129. [31] Flach, Frederic. (1988) Resilience: Discovering a New Strength at Times of Stress. New York, New York, New York: Fawcett Columbine. [32] O’ Connell Higgins, Gina. (1994). Resilient Adults: Overcoming a Cruel Past. San Francisco Ca: Jossey-Bass Publishers. [33] Kelly, Patricia and Clifford, Patrick. (1997). Coping with chronic pain: assessing narrative approaches. Social Work, 42, 266-277. [34] Davey, G.C.L. (1993). A comparison of three cognitive appraisal strategies: the role of threat devaluation in problem-focused coping. Personality and Individual Differences. 14, 535-546. [35] Lenhart, R.S., and Ashby, J.S. (1996). Cognitive coping strategies and coping modes in relation to chronic pain disability. Journal of Applied Rehabilitation counseling. 27, 15-18. [36] Byrant, Fred B. (1989). A four-factor model of perceived control: avoiding, coping, obtaining, and savoring. Journal of Personality, 57, 773-797. [37] Alter, C.L., Fleishman, S.B., Kornblith, A.B., Holland, J.C., Biano, D., Levenson, R., Vinciguerra, V., Rai, K.R. (1996). Supportive telephone intervention for patients receiving chemotherapy. Psychosomatics, 37, 425-431. [38] Faucett, Julia A. (1994). Depression in painful chronic disorders: the role of pain and conflict about pain. Journal of Pain and Symptom Management, 520-526. [39] Massie, M.J., Gagnon, P., Holland, J. (1994). Depression and suicide in patients with cancer. Journal of Pain and Symptom Management, 9, 325-340. [40] Vachon, Mary, Kristjanson, Linda, Higginson, Irene (1995). Psychosocial issues in palliative care: the patient, the family, and the process and outcome of care. Journal of Pain and Symptom Management, 10, 142-150. [41] Fife, Betsy L. (1995). The measurement of meaning in illness. Social Science Medicine, 40, 1021-1028. [42] Aronson, Kristan J. (1997). Quality of life among persons with multiple sclerosis and their caregivers. Neurology, 48, 74-80. [43] Regulating Physician-Assisted Death, 1994, retrieved 25 January 2007 from https://content.nejm.org/cgi/content/full/331/2/119. [44] Kiser, Jerry D. January 1996. Counselors and the Legalization of Physician – Assisted Suicide. Counseling and Values. ISSN: 01607960. v 40. n2 p. 127-31.