Swift vs. Machiavelli: Government

Swift vs. Machiavelli: Government Brandi Barnes We’ve all heard of governments over the years—anarchy, dictatorship, communism—who ruled with a firm hand and a blind eye. To be frank, some were just ruthless. But how do they lead? Strong? Weak? Or a little of both? Machiavelli’s purpose: how to rule in a manner that shows power and how to instill that power over the people swiftly. Swift’s purpose: recognize the kind of cold, calculating inhumanity of blunt rationalism when used to address social problems such as poverty as well as overpopulation.In â€Å"The Morals of the Prince,† he is somewhat encouraging the rulers to be harsh, but also be generous to show that he can give and take away because he has the authority. On the contrary, â€Å"A Modest Proposal† is stating that the coldness of turning a blind eye to the situation is one of inhumanity. To begin with, both prove their cases very differently, affecting their audience in th e most profound ways. Yet, there is one more effective than the other—Swift.Through the entire satirical piece, Swift is mocking the heartless attitude towards the poor. The wealth of a country is based on one thing: the poverty of the majority of its citizens. The English government was well aware of the two situations pointed out in this essay, yet they chose to sit there and do nothing about it. Instead, they withdraw their natural rights and dehumanize them by viewing them as a commodity.Swift’s comment– â€Å"That it will prevent those voluntary abortions, and that horrid practice of women murdering their bastard children†Ã¢â‚¬â€is one of the ways he shows the government taking away a natural right each mother has, but then goes on to say, â€Å"I doubt more to avoid the expense than the shame† to show how the government yet again is well aware of the dire situation, but they instead supported it by paying her to get rid of her child. Shiftin g into a new perspective, Machiavelli’s view towards the government is somewhat a paradoxical one.With each statement he makes, he presents is well; then contradicts. â€Å"He may make examples of very few, but he will be more merciful in reality than those who, in their tenderheartedness, allow disorders to occur,† this shows Machiavelli’s perspective on the government; saying that the one showing the consequences to the people know what happen if they disobeyed him instills that bit of fear, and that he will be more successful than a leader who is never stern and allows the people to walk all over him.By showing this certain authority, it ties back into his main purpose of establishing and maintaining power throughout their reign. To wrap things together, both Machiavelli and Swift are using a serious tone to present the same underlying topic: the government ruling. One is mocking it by showing how they pay money to have these children and help their families and the other is saying rule in a harsh but generous manner.In a plethora of ways, â€Å"A Modest Proposal† is exemplification to Machiavelli’s views on how to be an effective leader, but also contradicts on saying that some those exact views listed in â€Å"The Morals of a Prince† is inhuman and heartless. Swift directs his focal point to just that of poverty and overpopulation, allowing us to see a broader reasoning behind his mocking tone towards the government as opposed to Machiavelli using an array of examples. Through both readings, they present and utilize their sole purposes for writing them. Despite their contradictions, they are still very similar to one another.

Implications for Marketing Organizations Essay

Among these, the shift in the nature and growth rates of the world population has perhaps drawn much more attention of the business leaders because demographic variables reflect changes in consumer patterns and behaviors (Martins & Brooks 2009) which can impact their business practices. This report will examine the main trends in age structure of the global population and their implications to business strategies of marketing organizations throughout the world. The increase in ageing population is an important trend in many parts of the world, especially in developed countries (Madalina 2010), resulting mainly from the decline of fertility and increase in life expectancies (United Nations, 2011). After World War II, there was a sudden rise in the population which was termed as Baby Boom (Tombs & Seamons, 2010). They form an important target group for marketers. However, Tombs and Seamons (2010) pointed out that following the baby boom, the birth rate declined significantly in several nations such as Australia and New Zealand and a low fertility rate has existed since the mid 1970s. According to United Nations (2011), the aged population in the developed world is increasing rapidly and the number of old people will probably have outnumbered the young for the first time by 2050. People now prefer smaller families and this has led to a sharp fall in the birth rate. The improvement in living standards has a contributed to an increase in life expectancies. These factors have caused major changes in market patterns as well as in the type of goods being bought. For example, Gumbel (2008) demonstrated that the generation of Japanese women aged in their twenties who drove the growth in luxury fashion groups in most of the 1990s have mostly settled down to start families and buy apartments. As a result, the sales of luxury goods in Japan have fallen sharply. The age brackets which make up different proportions in the demography as a result of the changing age structure, have influenced the targeted markets and marketing strategy of companies (Tombs & Seamons 2010). The authors distinguish 6 different age groups within the Australian population, wherein each one has specific growth rates. The first category consisting of children below the age of five accounted for 6. 2% of the population in 2007. It is a promising market for companies who provide childcare services and children-related products. The population in the second group consisting of 10 to 19 year olds had declined at the beginning of the 1990s, but is gradually rising. This bracket is a targeted market for education, garment products, and entertainment. Post-teenagers and young adults aged 20 – 34 years constitute the grown-up category which was affected by the low fertility rate during the 1970s, causing its reduction through the 1990s. This group with a high disposable income purchase a variety of technologically advanced electronics along with branded garments. The fourth group of early middle aged people consisted of 13% of Australian population in 2007 and is predicted to increase to 23-25% by 2056 (Chandler 2008, cited by Tomb & Seamons 2010). The subsequent category is ‘Late middle age’ (Tomb & Seamons 2010, p. 161). Both these segments will have more importance for companies in the coming years as its share of the total population will grow gradually and consume a variety of high-priced luxury products. The last group comprising of senior citizens will also have a positive growth rate during the coming years similar to the two previous groups. These aged people are more interested in health care services, travelling and relaxation as opposed to the younger population which is easily attracted by technological commodities providing a positive social experience, creativity, innovation and uniqueness (Cuddeford 2012). A very important methodology behind television advertisements while targeting the middle aged groups is portraying celebrities in middle aged characters in order to please them by creating a sense of familiarity and thus, affinity (Diaz 2012). This is especially effective when several marketing ploys propagate youth culture. This approach is targeted towards expanding this segment which is attractive not only because of its increasing growth rate as the world population is ageing, but also because their exhibition of a loyalty related to service industry is considerably highercompared to the younger age groups (Paul & Patterson 2007).

Abandoned Dog’s 3-Year Wait for Owners Ends in Finding a New Home

†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ ENG 101H December 2, 2012 ABANDONED DOG'S 3-YEAR WAIT FOR OWNERS ENDS WITH NEW HOME The story that I want to share today is regarding an abandoned dog that waited three years for his owners to return to their house. When moving to another town, Chen was left abandoned in the house. He wondered around the property for three years, waiting for them to come back, sleeping in the carport and scavenging food scraps from a nearby grocery store. After years of waiting, a neighbor told Lisa Rendstrom from Chap’s Chow Rescue Foundation what was happening to Chen.She came to the site and bit by bit gained the dog’s trust and affection. She took him the their shelter where she started searching for a new owner to adopt the wonderful animal. It didn’t take long, because Ben Rupp saw his photo online, immediately felt a connection between them and flew to Georgia to take him. Chen is happy now, having a new home in Ohio, with an owner who f ell in love with him the moment he saw him. This story reminds me of a movie that is one of the most emotional movie that I have even seen : â€Å"Hachi, a dog tale†.Based on a true story from Japan, Richard Gere stars this great movie as a college professor who finds an abandoned dog and takes the poor lost animal in. The film follows the two as the man and animal soon form a strong and unexplainable bond. Every morning, the dog used to walk his owner to the train station and expect for him to arrive back from work, in the afternoon. But when, one day, the owner doesn’t arrive, having suffered a heart-attack and died at work, the dog keeps waiting in the train station for him.Days pass and the animal would not leave, even though his owner’s family put efforts in getting him home. The dog kept returning in the morning and in the afternoon, waiting for the train to arrive and his owner. After nine years of waiting in the same place, he dies in the train station. Hachi is a film about loyalty and the rare, invincible bonds that occasionally form almost instantaneously in the most unlikely places. Although most people are aware that there are more dogs and cats being born than there are people willing to adopt them, the actual number of unwanted dogs and cats is staggering.About 62 percent of all households in the United States have a pet and about 78. 2 million dogs and about 86. 4 million cats are owned in the United States. (ASPCA. org) Approximately 5 million to 7 million companion animals enter animal shelters nationwide every year, and approximately 3 million to 4 million are euthanized (60 percent of dogs and 70 percent of cats). (AnimalWorldNetwork. com) The connection that forms between a human and his pet animal cannot be described in words.But the question remains: Do our dogs feel the same things that we feel? In â€Å"The Botany of Desire,† author Michael Pollan observes that there are tens of millions of dogs in North Ame rica and only ten thousand wolves. He asks, â€Å"So what does the dog know about getting along in this world that its wild ancestor doesn’t? † The best explanation for everything canine, from the evolution of the wolf to the domestication of the dog — to the incredible emotional relationship that has emerged between the modern pet and its owner — is that dogs feel what we feel.Dogs have long been considered â€Å"man's best friend,† and they have certainly earned the title. The bond between humans and canines is unmistakable. Since the domestication of the dog, people have been drawn to them (and they to us). Dogs have helped us in so many ways and expect little in return. They have hunted with us, kept vermin and pests away, served the military and police, assisted the disabled, and faithfully remained our loyal companions. In turn, we care for them and maintain good quality of life.This is more than a fair trade. The bond you have with your dog begins the moment he comes into your life and never stops growing. And the two materials presented above prove that this is a â€Å"till death do us part† bond! The link to the web-material is: http://www. mnn. com/family/pets/stories/abandoned-dogs-3-year-wait-for-owners-ends-with-new-home Works Cited AnimalWorldNetwork. com. (n. d. ). Retrieved from http://www. animalworldnetwork. com/bsurpetstat. html ASPCA. org. (n. d. ). Retrieved December 2, 2012, from www. apsca. org Abandoned Dog’s 3-Year Wait for Owners Ends in Finding a New Home †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ ENG 101H December 2, 2012 ABANDONED DOG'S 3-YEAR WAIT FOR OWNERS ENDS WITH NEW HOME The story that I want to share today is regarding an abandoned dog that waited three years for his owners to return to their house. When moving to another town, Chen was left abandoned in the house. He wondered around the property for three years, waiting for them to come back, sleeping in the carport and scavenging food scraps from a nearby grocery store. After years of waiting, a neighbor told Lisa Rendstrom from Chap’s Chow Rescue Foundation what was happening to Chen.She came to the site and bit by bit gained the dog’s trust and affection. She took him the their shelter where she started searching for a new owner to adopt the wonderful animal. It didn’t take long, because Ben Rupp saw his photo online, immediately felt a connection between them and flew to Georgia to take him. Chen is happy now, having a new home in Ohio, with an owner who f ell in love with him the moment he saw him. This story reminds me of a movie that is one of the most emotional movie that I have even seen : â€Å"Hachi, a dog tale†.Based on a true story from Japan, Richard Gere stars this great movie as a college professor who finds an abandoned dog and takes the poor lost animal in. The film follows the two as the man and animal soon form a strong and unexplainable bond. Every morning, the dog used to walk his owner to the train station and expect for him to arrive back from work, in the afternoon. But when, one day, the owner doesn’t arrive, having suffered a heart-attack and died at work, the dog keeps waiting in the train station for him.Days pass and the animal would not leave, even though his owner’s family put efforts in getting him home. The dog kept returning in the morning and in the afternoon, waiting for the train to arrive and his owner. After nine years of waiting in the same place, he dies in the train station. Hachi is a film about loyalty and the rare, invincible bonds that occasionally form almost instantaneously in the most unlikely places. Although most people are aware that there are more dogs and cats being born than there are people willing to adopt them, the actual number of unwanted dogs and cats is staggering.About 62 percent of all households in the United States have a pet and about 78. 2 million dogs and about 86. 4 million cats are owned in the United States. (ASPCA. org) Approximately 5 million to 7 million companion animals enter animal shelters nationwide every year, and approximately 3 million to 4 million are euthanized (60 percent of dogs and 70 percent of cats). (AnimalWorldNetwork. com) The connection that forms between a human and his pet animal cannot be described in words.But the question remains: Do our dogs feel the same things that we feel? In â€Å"The Botany of Desire,† author Michael Pollan observes that there are tens of millions of dogs in North Ame rica and only ten thousand wolves. He asks, â€Å"So what does the dog know about getting along in this world that its wild ancestor doesn’t? † The best explanation for everything canine, from the evolution of the wolf to the domestication of the dog — to the incredible emotional relationship that has emerged between the modern pet and its owner — is that dogs feel what we feel.Dogs have long been considered â€Å"man's best friend,† and they have certainly earned the title. The bond between humans and canines is unmistakable. Since the domestication of the dog, people have been drawn to them (and they to us). Dogs have helped us in so many ways and expect little in return. They have hunted with us, kept vermin and pests away, served the military and police, assisted the disabled, and faithfully remained our loyal companions. In turn, we care for them and maintain good quality of life.This is more than a fair trade. The bond you have with your dog begins the moment he comes into your life and never stops growing. And the two materials presented above prove that this is a â€Å"till death do us part† bond! The link to the web-material is: http://www. mnn. com/family/pets/stories/abandoned-dogs-3-year-wait-for-owners-ends-with-new-home Works Cited AnimalWorldNetwork. com. (n. d. ). Retrieved from http://www. animalworldnetwork. com/bsurpetstat. html ASPCA. org. (n. d. ). Retrieved December 2, 2012, from www. apsca. org

Literature - In the Pond Essay Example | Topics and Well Written Essays - 1000 words

Literature - In the Pond - Essay Example Desperately longing to escape from the single room he and his wife and child have been living in, Bin’s rage is induced by the fact that he fails to obtain an apartment that would provide him and his family with a better life. He feels he has been treated unfairly and that others have been rewarded for political reasons. Unwilling to resort to something as low as bribery, he subjects himself as well as his family, to the endless waiting list for the new apartment, despite his seniority and right to one. It is evident that for some time Bin was able to function in this society quite well. But, the moment he required more than he was given, his dissatisfaction emerged from the depths of his soul. Because, in such a society, one’s power equals the amount of money he owns or people on higher positions that he knows. Effort and hard work are unjustly neglected as unnecessary qualities in a worker, while those that blindly and brainlessly follow orders, are being pushed up th e corporate ladder, praised and rewarded. Seething with anger, the hapless Bin turns to the words of the Han dynasty scholar Wan Chong to find solace. His talents as a calligrapher go unappreciated, and after working all day, he can only give vent to his artistry by night. This is where Bin’s personal epic battle between good and evil commences. He gets the idea to use his talents to gain revenge by placing a satirical cartoon in the provincial paper, which is full of vigor, almost resembling a miniature revolution. Feeling utterly overcome by rage, he does not think things through, but acts rashly, and later wishes his wife stopped him. But, it is already too late. His rage has put into motion something much larger than himself and now that it is out, he cannot stop it anymore. It is said that a good artist can channel any emotion into a work of art, and this is exactly what Bin does. Feeling as low as one can possibly feel, he transforms his anger and utter dissatisfaction into expressive art. He uses his almighty calligraphy pen to fight the establishment and this is the only part of him they are not able to put down and control. It is from this part of his soul that his rebellion is teeming forcefully. Bin becomes transformed from a mindless drone into the everyman of human society, the universal man whose spiritual awakening has just found him and whose dreams have just been set in motion, despite his circumstances, despite his possibilities, despite his reality. Party leaders, secretly alarmed by the accuracy and cleverness of the cartoon, rally hastily. Calling a workers meeting, they bluster and sneer over the political incorrectness of his artwork. They respond with a pay cut and Bin creates another art piece that attacks their greed and their anti-revolutionary tendencies. Bin never backs down from the threats launched his way, and occasionally with his wife’s prodding, he continues to look for justice at the commune level, then with th e county hierarchy, and finally in Beijing. Because his case becomes so famous, his supervisors are unable to just have him beat up, or to simply fire him. Bin tilts at windmill after windmill, undaunted, unwilling to give in to what he knows is wrong. His supervisors dock his pay, humiliate him, and refuse to employ his talents as a calligrapher and choose to hire an outsider instead, but he still stubbornly persists in his efforts. Both sides are caught in an accelerating spiral of recriminations and revenge, the universal human cycle of

Assessment Evidence Essay Example | Topics and Well Written Essays - 500 words

Assessment Evidence - Essay Example And the various seasons: summer, fall, winter, spring. Students will have an oral test at the end of this unit to test their understanding. The purpose of the test will be to test whether they can differentiate and describe various element of weather and seasons. Some of the issue that the student will be asked to describe are: what is whether and why do we care? Describe the various elements of weather and seasons? How do season and whether affect our environment? How do seasons and weather affect the way we live? Student will be given an opportunity to ask questions to clarify anything. After every lesson student will be asked to do home work about a part discussed in class in class. The homework will be an activity question; the student will be allowed to engage their brothers, sister, and parents. The aim of the homework will be to ensure the student develop interest in with the environment. And ensure they discuss it even out of class. Example of such assessment is: 3) The teacher will describe the various season and weather experienced in the different place, and the activities carried out there, then give advantages and disadvantages of living in such places, Ask students if they would enjoy living in a place like that. Let the student explain their

How to utilize and enhance City Year social media Research Paper

How to utilize and enhance City Year social media - Research Paper Example The paper tends to briefly analyze the role and significance of social media in terms of creating considerable awareness through developing adequate planning for San Antonio City Year which can protect students from rising dropout crisis within the state. The discussion in this essay will also focus on demonstrating effective communication and customer service facilities which can enable San Antonio City Year to efficiently increase its number of members from both students at the risks of dropout and AmeriCorps members. RECOMMENDATIONS Demographic Analysis Of Social Media In San Antonio. According to the present day context, the association with social media has been witnessed to significantly increase amid the young adult population within the age group of 16-24 years. In relation to the observation of present usage of social media, it can be identified that a few of the major social networking sites including Facebook, Twitter and YouTube among others are widely used by the young a dults in San Antonio. Facebook. By providing exceptional experience of social media service to the millions of global users, Facebook has established itself as one of the leading and dominant organizations around the world. In accordance with the present day context, Facebook has been able to accumulate around 1.1 billion of Monthly Active Users (MAUs) across the different regions of the world (Facebook â€Å"Investor Relations†). Moreover, Facebook has also been identified to be one of the leading social media sites, which has established a follower base of young adults within the age group of 16-24 (Fuller 19-21). Twitter. Twitter can also be considered as an effective social media resource for San Antonio City Year in order to build a strong community. In accordance with the observation of the global social media environment, Twitter has been able to amass almost 500 millions of global users across the different geographical locations. This social networking site incorpora tes a large number of active female user accounts as compared to male and it is highly used for higher educational purposes. Twitter generally incorporates a large number of users within the age group of 25-54 years (PanARMENIAN Network, â€Å"Twitter Approaching 500 Million Users Milestone†). YouTube. YouTube can also be stated as an effective source of social media which is widely used to share videos to a number of users. The site has been able to obtain almost 1biilion of active users from diverse age groups. In relation to the age-demographic view of YouTube, it can apparently be observed that the site mostly incorporates the users within the age group of 25-54 years (Laura and Wankel 16-19). In relation to the aforesaid observations of the different social media sites, it has been determined that the integration of Facebook within the awareness activities will be a major and beneficial selection for San Antonio City Year to reduce the potential dropout rates within San Antonio. Moreover, the integration process can also provide adequate support to the San Antonio City Year to build an effective relationship with the students at higher risk of dropout along with facilitating to mitigate such risks. SOCIAL MEDIA ON SMARTPHONE The rapid technological development

Managing people Master Essay Example | Topics and Well Written Essays - 2000 words

Managing people Master - Essay Example (Jehn & Mannix (2001) identify three main types of the group conflict: task conflict; relationship conflict; process conflict. Another researcher, Robbins (2005) singles out: functional conflict and dysfunctional conflict. In other cases, conflicts undermine the group process and set the stage for ongoing problems and reduced group effectiveness in the future. Some recent research by Jehn & Mannix (200) examines the longer-term effects of conflict on group performance. The research also considers what they call "task complexity" as a moderating variable, which aligns with the notion of quantitative and qualitative balance in relation to conflict. An alternative view is proposed by (Hede 1990) who states that there two factors are needed to produce conflict: cognitive disharmony and affective disharmony. Group dynamics depends upon group norms, group cohesiveness and group roles assigned to different group members. McKenna (1994; in Hayes 2002) state that there are seven factors influenced group cohesiveness: similarity of attitudes and goals, time spent together; isolation of group from others; threats from outside group, size; stringent entry requirements; rewards for group performance; problems. The small group is a subsystem within the larger organization. As such, it is subject to the same forces as the larger system. The behavior of one group member affects all of the others. Influencing behavior carries beyond the face-to-face meeting. Individual members interact "off-line" in settings other than meeting rooms. Schutz's 3-stage Model will help to identify and describe the main problems occurred in Greenline. According to his model, there are three main stages of group dynamics: stage 1: In or Out (when members unsure about joining, explore relationships); stage 2 - Top or Bottom (when conflicts and power struggles among members), stage 3: Near or Far (members make commitment and clarify relationships; emotional integration of members). Another model of group development is proposed by Margerison & McCann (1995). They explain that a leader or central person is a wheel of the group. Such group is generally more satisfied with the communication pattern and results than the other members. He or she can, however, suffer from information overload and have difficulty making judgments or arriving at a solution. Managers also have the responsibility to establish and maintain the climate of the groups that work in his or her department. When opportunities are provided for free and open discussion, pe ople tend to feel more personal satisfaction and are generally more productive. Another important concept is groupthink. It is defined as "the mode of thinking that persons engage in when concurrence-seeking becomes so dominant in a cohesive in-group that it tends to override realistic appraisal of alternative courses of action" (Irving Janis, 1971: 43). If a group has groupthink, managers who succeed in creating trusting, open exchanges between people and a high level of cohesiveness among members can keep disagreement and conflict in perspective. Problem Identification Greenline many individual elements affect the way the top team operates: the reason

Spirituality Essay Example | Topics and Well Written Essays - 1250 words - 2

Spirituality - Essay Example The first is a moral code of conduct and justification that will guide health care providers to tend to patients in a manner that is in alignment with religion. Such as the fact that they cannot present life threatening drugs or force people to take a drug that may cause death. At the same time, women cannot be advised of abortion etc. Secondly the doctor patient relationship needs to be built on the element of trust; the patient is entitled to receive all the information regarding treatment, health care and any aspect of a procedure that they have to undergo. Even though the provider is the true healer and is believed to be so by the patient as well, all sides of the story is a duty of the doctor to the patient. Thirdly, patients are autonomous, that is, they are allowed to make any decision they want to, after being presented all the facts of the situation. At the same time, health care providers have to act like good citizens, taking it on their conscience to care for the patient and heal them; and not just go through with this procedure in a mechanical fashion, but to be caring and loving and compassionate towards the patient. God will only show mercy to him who showed mercy on his creation, and so providers need to offer not just treatment but compassion and mercy to patients, praying for their well-being and taking it as a duty as God’s servants to take care of his creation. At the same time there is the concept of non-maleficence in Christianity; which essentially translates into â€Å"never harm anyone.† According to this principle, health care providers need to be such that they give the right kind of prescription to the right patient and they need to assess whether a particular treatment would harm or benefit the patient in question. Christianity also believes in the principle of justice. Therefore patients are all to be treated equally and fairly, and treated till depth of the provider’s ability as

American Struggle for Independence Personal Statement

American Struggle for Independence - Personal Statement Example The American Revolution was the first of its kind, and it stimulated an effect on the world since then. Philadelphia, one of the nation's first capitol, bears American revolutionary landmarks inasmuch as it is were a lot of colonial meetings the engendered the Continental Congress took place. Last week, I ventured into exploring the Constitution Center to recapture the ambience of the struggles and the inception of our new nation. First of all, all of the relics at Constitution Center were preserved to keep its luster of its time. I was excited to see the revolutionary cannon, and I appreciated how much our weapons have evolved from then. The area evoked an ambience of the original colonies; the colonial apparel ushered in that atmosphere. I loved the arsenal area and enjoyed the history of guns and their development. I grew in admiration of the First Lady's gallery. I never perceived women would be given credit in their involvement of helping the nation given the well documented past of social parameters placed against women. This was especially depicted in this gallery. This area taught me growth of the roles of the First Lady in politics. Also, I admired the earlier first lady sense of style. One person explained the cultural struggles of women in terms of garment. She depicted that women were not as exposed or flamboyant as they are today but were "ultra-reserved." Women of earlier times wore metal cylinders around their thorax which can induce physical discomfort and pain. Over decades, these metallic plates became woolen but it still stimulated discomfort because of its tightness. However, many did not object to that pain for they accepted this as normal practice. The First Lady began to be internationally recognized as celebrities which in turn coerced or persuaded these women to live up t o their newfound title. Many dresses that the First Ladies wore during presidential balls, concerts, and other special occasions were exhibited. A lot of the exhibits were outside to usher in that colonial atmosphere during the war. I really liked the battle scenes depictions. From the exhibits that were indoors, I was inspired by the caricatures that resemble the first and second Continental Congress. In my mind, that exhibit represented the authentic pre-American regal style. I drew constant admiration for that. Furthermore, if ran the exhibits, I may leave just the way they are. This trip has richly reinforced my personal view of the Revolution and Constitution. The Constitution as a legal document was constructed by men desiring to build a country on equal rights for all and to eliminate monarchy. As aforementioned, many nations have used this framework to develop their own constitution. Countries such Haiti, South Africa, Central America, South America, and others study and marvel at event that seemed impossible. Soon, it inspired their liberation from tyranny and mistreatment. Reminiscing on those thoughts at the Constitutional Center revealed to that the U.S. constitution is more than a document, but a pedantic example for all. I also saw the original flag of the colonies in which I have never seen before. I saw the growth of the flag in terms of stars. I never knew each color of the flag had a meaning. I was also taught that it was disrespect to allow the flag to touch the floor. Another interesting aspect that the administrators taught me was that the importance of drummer boys in the army. The beat of drums engendered an ambience to mentally prepare the

Reflective Account Essay Example for Free

Reflective Account Essay This seemed to keep his mind off worrying about were his wife or daughter was and stopped him from wanting to walk about the ward. After a while the patient asked if he could lie down for a while, and I explained that this was ok. I lowered the bed for the patient as low as it would go, to prevent the patient from falling or injuring himself while climbing into the bed. By doing this I was following the guidelines set out by the health and safety at work act 1972 and carrying out risk assessments to prevent harm to myself or others. Once the patient had got into the bed safely I put the bed side up to prevent him from falling out while he was sleeping, I then gave him his buzzer. Before leaving the room I asked the patient if he would like the room door left open or closed over, by doing this I was promoting the patients right to choice and individuality. I then left the room and closed the door as the patient had requested, and told the staff nurse in charge of him, that he was now sleeping, and that I had emptied his catheter bag and updated the fluid balance chart. I had to tell the staff nurse that I had left the room, so that if anything happened they knew that I was not there, as I would be accountable for it. Being accountable for my actions is one of the NMC code of conduct and is in line with professional accountability. I think that this task was very fulfilling as I was able to help other staff around me, as well as keep a patient calm. I enjoyed talking to the patient and found it very interesting. It also allowed me to practice keeping patient’s charts up to date. References

Arguments For and Against Euthanasia

Arguments For and Against Euthanasia Euthanasia: Whose decision is it I. Introduction In a 1988 issue of the Journal of the American Medical Association, an article titled Its Over Debbie describes how an anonymous doctor administers a fatal dose of morphine to a woman dying of ovarian cancer (Anonymous, 1988). In a 1989 issue of the New England Journal of Medicine, ten doctors associated with the nations leading hospitals and medical schools declare their belief that it is not immoral for a physician to assist in the rational suicide of a terminally ill person (Wanzer, et. al., 1989). In 1991, the New England Journal of Medicine published a detailed account written by Dr. Timothy Quill which discussed his decision to help a patient suffering from leukemia commit suicide (Quill, 1991). In 1990, Dr. Jack Kervorkian uses his suicide machine to help a woman suffering from Alzheimers disease, one Janet Adkins, end her life in the back of a Volkswagen bus (Risen, 1990). Janet was the first of twenty patients who have been aided by Kervorkian in the past three years. He rem ains committed to his practice. In 1991 the Hemlock Society publishes a how-to manual on committing suicide. Entitled Final Exit, it zooms to the top of the national best seller lists and stays there for several weeks (Altman, 1991). Each of these events has served to provoke ever widening media coverage of the issues surrounding euthanasia and physician assisted suicide, and a national debate has arisen around these practices. This debate is not merely limited to attorneys and physicians. Suddenly, these issues and this debate are now a part of life in mainstream America, and many Americans face dilemmas that did not exist in simpler times; dilemmas that many would rather not have to face. II. Review of the Literature a. Euthanasia: The Nature of the Debate It is this sudden change in the way Americans are dealing with death, the nature and scope of the debate about dying, which prompts this analysis of the issues surrounding euthanasia. This debate is largely a debate about what is ethical. Questions the debate attempts to answer include: Is it right to commit suicide? Is it ethical for someone else to help? Is it right to put others to death at their own request or at the request of family members? These questions are important because they help to define our society and our culture. The way people deal with and respond to issues of life, ritual, and death serves to shape the nature of our society. This is why society must attempt to decide what is right; what is ethical conduct for the various actors in our communities when we face death. There are several reasons why this debate has surfaced in the 1980s. Death is nothing new, it has existed for thousands of years. Each culture has developed its own rituals and mechanisms for dealin g with death. These mechanisms serve to provide solace, a sense of continuity, and allow the culture to continue even as the members of the community cannot. However, our own culture has experienced many shattering changes that have altered the nature of dying. Suddenly we are forced to rethink the issue of death and we must decide what types of behavior are ethical when someone is dying. Before we can examine the debate about the ethics of dying, we must examine why the debate exists. Perhaps the main reason that death has changed in western culture has to do with advances in medicine and technology. Many of the diseases that have historically killed people are now no longer a threat to most individuals. Medicine has made a variety of advances in the treatment of diseases such as smallpox, tuberculosis, malaria, pneumonia, polio, influenza, and measles. People now rarely die of such traditional causes. Life expectancy has risen to almost 75 years in the United States. The quality o f life has also changed fundamentally during the past 100 years. Not only does almost everyone in the United States have enough to eat, but people eat higher on the food chain. There is a great deal more meat and animal fat in modern diets. Just these differences alone have changed death significantly. People now develop heart disease, adult onset diabetes, cancers, and AIDS. These types of diseases are more the result of lifestyle than bacteria. With these new diseases, suffering is often more prolonged and treatment is frequently quite painful. Also, as people are living longer, the diseases of the aged have become increasingly prevalent. Many more people now suffer from problems like senile dementia and Alzheimers disease. These diseases ruin the mind while preserving the body, allowing life to continue long after any quality that the life might have is gone. If what we die of has changed, perhaps the way that we die has changed even more. Throughout history, death has been a family affair. People usually died in the home after a short bout with an illness or as the result of an accident. Today, increasingly, death occurs in an institutional setting such as a convalescent home or a hospital, after a variety of technologies are applied in an attempt to prolong the life of the sick person. Often these technologies can be quite effective. People can now live for months and even years attached to a variety of tubes and technol ogies. About 75% of all deaths in 1987 occurred in hospitals and long term care facilities, up from 50% in 1950 . . . The Office of Technology Assessment Task Force estimated in 1988 that 3775 to 6575 persons were dependent on mechanical ventilation and 1,404,500 persons were receiving artificial nutritional support. This growing capability to forestall death has contributed to the increased attention to medical decisions near the end of life. (CEJA, 1992, p. 2229) People realize that the chances of facing the institutionalization of death increase daily, and they feel a profound lack of control. Surveys have consistently indicated that a large majority of people in the United States would like to be allowed to end their lives before incurable and painful diseases finally kill them (CEJA, p. 2229). Because of the changes that have impacted death, with regard to both how and where we die, the debate about how we should be allowed to die has been renewed. This paper will examine the s everal facets of this debate. It will define the terms that are relevant to the debate, examine the legal state of euthanasia today, discuss the ethics of euthanasia by examining arguments made by proponents and opponents of euthanasia, and by applying several Normative Ethical Theories to the issue. Finally, it will explore the power implications that infuse the debate on euthanasia and present arguments in favor of moving toward a care based ethic of dying and away from the current rights based ethic. b. Definitions If we are to effectively understand the debate about the right to die in the United States, it is imperative that a few basic terms be understood. The first and most important term is euthanasia. Originating from the Greek terms eu (happy or good) and thanatos (death), euthanasia means literally happy death or good death. The American Medical Associations Council on Ethical and Judicial Affairs defines the term as follows: Euthanasia is commonly defined as the act of bringing about the death of a hopelessly ill and suffering person in a relatively quick and painless way for reasons of mercy. In this report, the term euthanasia will signify the medical administration of a lethal agent to a patient for the purpose of relieving the patients intolerable and incurable suffering. (p. 2230) Other sources have defined euthanasia variously: The act or practice of painlessly putting to death persons suffering from incurable conditions of diseases. (Wolhandler, 1984, p. 363), . . . to refuse un wanted medical treatment or to have ongoing care withdrawn even though the patient will die if treatment is terminated. (Adams, et. al., 1992, p. 2021). Euthanasia is a general term that can actually mean a variety of different things depending upon the context in which it is used. For this reason, a number of supporting terms has become the convention when discussing euthanasia. These terms help to narrow the subject matter and distinguish between different types of euthanasia. The important terms that help to subdivide and classify euthanasia by type are voluntary/involuntary and active/passive. Voluntary euthanasia is a death performed by another with the consent of the person being killed. This consent may be in writing as in the case of a living will or advance directive. Involuntary euthanasia is a death performed by another without the consent of the person being killed. The AMAs Council on Ethical and Judicial Affairs makes three distinctions concerning consent and euthanasia: Voluntary euthanasia is euthanasia that is provided to a competent person on his or her informed request. Non-voluntary euthanasia is the provision of euthanasia to an incompetent person according to a surrogates decision. Involuntary euthanasia is euthanasia performed without a c ompetent persons consent.(p. 2230) Wolhandler compares the terms in a different context.Those who condemn euthanasia of both kinds would call the involuntary form murder and the voluntary form a compounded crime of murder and suicide if administered by the physician, and suicide alone if administered by the patient himself. As far as voluntary euthanasia goes, it is impossible to separate it from suicide as a moral category; it is, indeed, a form of suicide. Voluntary euthanasia may involve participation of second parties. (p. 366) The distinction between active and passive euthanasia is not nearly as clear as the previous distinction. Although many authors claim that the difference between the two types cannot be identified or is irrelevant at best, much of the debate on the subject is over this distinction and most of the current legal issues turn on this distinction. While this paper will contend that the difference between the two should not be recognized, it is both useful and important to know where the line is drawn. The AMA, which is strongly opposed to active euthanasia, has seen fit to endorse passive euthanasia in appropriate situations. The Council on Ethical and Judicial Affairs makes the distinction as follows: The physician is obligated only to offer sound medical treatment and to refrain from providing treatments that are detrimental, on balance, to the patients well being. When a physician withholds or withdraws a treatment on the request of a patient, he or she has fulfilled the obligation to offer sound treatment to the patient. The obligation to offer treatment does not include an obligation to impose treatment on an unwilling patient. In addition, the physician is not providing a harmful treatment. Withdrawing or withholding is not a treatment, but the foregoing of a treatment. (p. 2231) According to Wolhandler, (p. 367) it is t he nature of the acts performed by the second party that distinguishes between active and passive euthanasia. The courts have held that acts of omission (removal of respiratory assistance, hydration, and feeding tubes) are allowable behavior. Although unplugging a respirator and switching off a dialysis machine are arguably acts of commission, an increasing number of judges and commentators have accepted these acts as permissible passive euthanasia in both voluntary and involuntary settings. Gifford (1993) describes the difference between the two types of euthanasia this way: Passive euthanasia involves allowing a patient to die by removing her from artificial life support systems such as respirators and feeding tubes or simply discontinuing medical treatments necessary to sustain life. Active euthanasia, by contrast, involves positive steps to end the life of a patient, typically by lethal injectiond (p. 1546) The right to passive euthanasia has also been termed the right to die by some authors (Adams, et. al., p. 2021-22). With an understanding of the different types of euthanasia, we can now define some other key terms. It is important to understand how physician assisted suicide differs from euthanasia, and it is also necessary to define the terms advance directive and competence since they are crucial in determining the difference between voluntary and involuntary euthanasia. The term physician assisted suicide is somewhat self-explanatory. It occurs when a physician provides aid to a patient so they can commit suicide. However, it is also necessary to see the difference between this type of action and euthanasia. The AMAs Council on Ethical and Judicial Affairs states that Euthanasia and assisted suicide differ in the degree of physician participation. Euthanasia entails a physician performing the immediate life ending action (e.g., administering a lethal injection). Assisted suicide occurs when a physician facilitates a patients death by providing the necessary means and/or information to enable the patient to perform the life-ending act (e.g., the physician provides sleeping pills and information about the lethal dose, while aware that the patient may commit suicide). (p. 2231) It is important to realize that the difference between euthanasia and assisted suicide lies in the behavior of the physician. This difference in behavior has recently become a major legal battleground that will be explored in the following pages. The advance directive has recently become an important new device to aid the terminally ill. Many states have legalized the advance directive, partly in an attempt to avoid dealing with problems associated with active euthanasia, and partly to help ease the burdens on the dying and their families. Singer (1992) provides a good definition of advance directive and explains how it is used. An advance directive is a written document completed by a competent person that aims to guide medical treatment after the person becomes incompetent. There are two types: instruction directives, which focus on the types of life-sustaining treatment that the person would want under various clinical situations, and proxy directives, which focus on who the person would want to make health care decisions if the person were unable to do so. (p. 22) The advance directive is useful because it can theoretically eliminate the need for involuntary euthanasia. It ensures that a voluntary decision is made in advance, even if the individual could not make such a situation at a later date. If everyone made use of the advance directive, there would be no need to debate policy decisions that must be made in the case of an incompetent person on life support. Because advance directives have neither been accepted nor widely used by the general public, many of the problems that could potentially be solved remain. This situation caused right to die groups in both California and Washington to propose ballot initiatives that would legalize active euthanasia (Gifford, p. 1550-51). Although active euthanasia is not legal in any United States jurisdiction, passive euthanasia is generally allowed at the request of a competent individual. Because of this it is critical to understand what constitutes competence. Courts have defined legal competence as the mental ability to make a rational decision, which includes the ability to perceive, appreciate all the relevant facts, and to reach a rational judgement upon such facts. In the euthanasia context, legal competence is the incurable s ability to understand that in requesting active euthanasia he is choosing death over life. Only clear and convincing evidence should suffice for a finding of an incurables competence. (Wolhandler, p. 366-67) c. The Legal State of Euthanasia With a knowledge of the meaningful terms that will be involved, it is important to discuss the legal state of euthanasia in the United States today. As technology has placed more and more people on life sustaining devices in this country, the courts have had to deal with several cases that pertain to euthanasia in a variety of ways. This section of the paper is designed to review those cases briefly and to assess how the rulings in those cases have set the policy for the practice of euthanasia today. The courts first dealt with euthanasia in the Quinlan case in 1976. Karen Ann Quinlan lapsed into a coma after mixing a variety of pills and alcohol at a party. After it became apparent that she would not be revived, her parents went to court to have her respirator removed. The New Jersey Supreme Court ruled that her parents had the right to have the respirator removed and that Karen be allowed to die. Ironically, because her parents did not request removal of feeding and hydration tubes , she survived nine more years curled in a fetal position in a New Jersey rest home (Wolhandler, p. 366). In this case, the New Jersey court effectively sanctioned nonvoluntary passive euthanasia. The next prominent case was decided by the New York Supreme Court in Superintendent of Belchertown State School v. Saikewicz. Here the court found that a competent patient had the right to refuse medical treatment, allowing for a patient to decide in cases of voluntary passive euthanasia (Gifford, p. 1575-76). Later, in Satz v. Perlmutter, a Florida District Court of Appeals came to essentially the same conclusion (Wolhandler, p. 372-73). In Severns v. Wilmington Medical Center, the Delaware Supreme Court gave the husband of a comatose woman the right of guardianship and the authority to remove her respirator or withhold other treatment as he saw fit. In this case the court relied on previous decisions made in Quinlan, Saikewicz, and Satz for its finding (Wolhandler, p. 373). In Thor v. Su perior Court (California), the court granted the request to withhold treatment from a severely depressed quadriplegic only after a psychiatric evaluation determined that the request was based on poor quality of life and not just on severe depression (Pugliese, 1993, p. 1326). The courts have not restricted the right of passive euthanasia to just the terminally ill. Elizabeth Bouvia was a relatively young woman who suffered from severe cerebral palsy and attempted to starve herself to death in a California hospital by requesting the removal of a nasogastric feeding tube. She was denied this request because the hospital feared it would be party to suicide. The California court of appeals ordered the physicians to remove the tube and argued that she had the right to enlist the assistance of others in ending her life (Sprung, 1990, p. 2213). The courts have also found that doctors and hospitals must at least obtain consent from third parties that would have a significant interest in the patients outcome if the patient is incompetent. In the case of Helga Wanglie, a Minnesota court denied a hospital administrator permission to disconnect her respirator against the wishes of her husband (Gifford, p. 1571). In sum, these cases indicate an emerging consensus that courts will generally allow treatment to be withheld from patients who are terminally ill if it is in the best interests of the patient and at the request of patients or family members. It is this emerging consensus that made the U.S. Supreme Courts decision in the Cruzan case so interesting. In the only euthanasia case heard to date by the U.S. Supreme Court, the justices, in a 5-4 decision, allowed to stand the decision made by the Missouri Court of Appeals not to disconnect the life support apparatus from Nancy Cruzan (Cruzan v. Director, Missouri Dept. of Health, 1990). Although the court did find that a right to refuse treatment could be found in the Due Process clause of the Fourteenth Amendment, and did not prohibit the courts from looking in other areas for this right (Adams, et. al., p. 2025), it also upheld the right of the State of Missouri to require . . . clear and convincing evidence that Ms. Cruzan would have desired withdrawal of these treatments. (Newman, 1991, p. 175). In the realm of physician assisted suicide, only two major cases have been decided. In the case against Dr. Timothy Quill that arose because of the publication of his article in the New England Journal of Medicine, the grand jury for the state of New York refused to return an indictment (Bender, 1992, p. 524). In the more publicized case of Dr. Jack Kervorkian, the courts have not yet decided on the constitutionality of the Michigan law that bans physician-assisted suicide. Kervorkian is currently free on bond and continues to aid other patients who wish to commit suicide (Pugliese, p. 1300-05).(1) A brief assessment of the cases described above indicates that the courts have essentially legalized voluntary passive euthanasia, finding justification to refuse or have medical treatment withheld in the constitutional right to privacy, the common law right of self determination, or the more general concept of autonomy (Gifford, p. 1575-78). With regard to involuntary passive euthanasia, the courts are generally supportive of the practice, but they have the right to insist on a more stringent standard of evidence before approving such procedures. The courts have generally employed a balancing test that weighs the patients right to privacy and self-determination against the interest of the state in preserving life. The interests of potential third parties that might desire that the patient continue to live, and the ethical image of the medical profession (Adams, et. al., p. 2022). In cases of assisted suicide, some states have laws against the practice, the AMA forbids it, most juries are refusing to find the actors guilty, and the courts have yet to decide the question. Both voluntary and involuntary active euthanasia remain illegal. d. The Debate About Euthanasia The movement to legalize active euthanasia has existed for quite some time. Initially popularized in Britain during the 19th century, it gained some adherents in the United States during the 1920s. It was the Nazi program of active euthanasia in the 1930s and 4os that cast a pall of disrepute over the practice that remains today. The revival of this movement today can largely be attributed to the onset of the issues discussed at the beginning of this paper, and to the efforts of the Hemlock Society, a group of individuals that actively promotes the right to dignified death. The Hemlock Society recently promoted ballot initiatives in both Washington and California that would have legalized active euthanasia in those states (Gifford, 1993). This revival of the right to die movement has led to hotly contested debate about the practices of active euthanasia and physician assisted suicide. This paper will attempt to encapsulate this debate by presenting the arguments made by both opponents and supporters of these procedures. Since arguments made by both sides are used in cases of euthanasia and assisted suicide, the generic term euthanasia is used for simplicity to suggest the concept of aided death unless otherwise indicated. Those opposed to euthanasia and assisted suicide present a variety of arguments in support of a ban. e. The Case Against Euthanasia Euthanasia destroys societal respect for life. By becoming commonplace and used in medical practice along with more traditional methods of healing, society becomes desensitized toward death to the point where life is no longer valuable. This attitude serves to degrade humanity and leads to a variety of social ills. In a society that devalues life, people have no compunctions about committing violent crimes and murdering others. The overall quality of life becomes seriously undermined and society as a whole deteriorates (Doerflinger, 1989, p. 16-19, Koop, 1989, p. 2-3). Once euthanasia becomes legal, opponents contend, the potential for abuse at the hands of caregivers vastly increases. Closely related to this argument is the argument that those who enjoy the exercise of power over others might become intoxicated with it and actually come to enjoy killing. One step down the path toward euthanasia simply makes it that much easier in the future to take further steps. This argument is al so referred to as the wedge theory or the slippery slope. One of the most outspoken opponents of euthanasia, University of Michigan professor of law Yale Kamisar, has articulated a three pronged attack that utilizes the wedge theory, the risk of abuse, and the risk of mistake. The proponents of the wedge theory argue that Once society accepts that life can be terminated because of its diminished quality, there is no rational way to limit euthanasia and prevent its abuse. According to this theory, voluntary euthanasia is just the thin edge of a wedge that, once in place, will be driven deeply into our society. Kamisar concludes that legalized voluntary euthanasia inevitably would lead to legalized involuntary euthanasia because it is impossible to draw a rational distinction between those who seek to die because they are a burden to themselves and those whom society seeks to kill because they are a burden to others.(2) (Wolhandler, p. 377) Many who raise the wedge or slippery slope a rgument use the Nazi experience with euthanasia as an empirical example of this process in action. They argue that a public policy of murder inexorably follows from an initial, limited step, namely the adoption of a carefully defined euthanasia program, and that a program designed to get rid of those with lives unworthy of life quickly degenerated into the holocaust (Newman, p. 167). What follows is a description of the Nazi euthanasia program excerpted from Liftons (1986) book: National Socialist euthanasia or mercy death was a program of killing persons with unworthy lives. These persons were not moribund, and their families, with the rarest exceptions, wanted them to live. It was not a good death, as the word denotes, but a systematic program of killing without any mercy whatsoever . . . The program, referred to in the National Socialist bureaucracy as T4, was not based on any law, but was initiated by a secret order traceable to Hitler and his chief physician, Karl Brandt . Ment al hospitals were required to report all chronic schizophrenics, manic-depressives, mental defectives, epileptics, and later, debilitated old persons. A separate division, the Public Transport division for the Sick, took care of the collection and transport of such patients to institutions where they were put to death . Relatives received false death certificates and even letters of condolence . . . It is estimated that during two years of this program, ninety thousand persons went to their deaths. While this description of the Nazi euthanasia program is indeed chilling, it provides within it a devastating attack against using it as justification for the slippery slope argument. Proponents of euthanasia in the United States point out that the Nazi program was not one of euthanasia, but a program of mass murder disguised as euthanasia. Gifford (p. 1570) sums up the response of several authors by stating that The Nazis hid their racist, eugenic agenda behind the term euthanasia, termi nating in secret the lives of undesirables. It must never be forgotten that the Nazi euthanasia program was never euthanasia at all. That the Nazis co-opted the term for their own purposes should not obscure the fact that their motive was, from the very beginning, entirely different from that of todays euthanasia proponents. The current euthanasia movement is anything but covert. The Hemlock Society and other supporters of the right to receive aid in dying have spent millions of dollars to publicize their efforts. In this context, death is presented as a positive alternative to pain and suffering, not a utilitarian tool. Proponents of euthanasia also attempt to refute the slippery slope argument in a variety of other ways. They contend that the current mechanisms used by the courts could easily prevent any slide toward involuntary euthanasia,(3) that the current practice of passive euthanasia proves that the slope isnt all that slippery since we havent witnessed any massive killing programs, and that the example of how forced sterilization in the U.S. has diminished rather than increased, provides a more appropriate example to rely on. Even Callahan (1989), a vocal opponent of active euthanasia, admits that the Nazi experience is not particularly applicable to the U.S. experience and that Lives are not b eing shortened. They are steadily being lengthened, and particularly for those who are the most powerless: sick children and the very old, the mentally and mentally retarded, the disabled and the demented (p. 4). Newman (1991) also attacks the concept of the slippery slope itself. Arguing that just pointing out that one type of action could conceivably lead to another constitutes a very unpersuasive argument and that for the premise to hold true, it must be shown that pressure to allow further steps will be so strong that these steps will actually occur. He also reminds us that such arguments are frequently abused in legal and social policy debate (p. 169). Besides Kamisar, the risk of abuse argument has also been put forth by a host of other authors who variously claim that assisted suicides might result in flagrant murders that may be perpetrated by deliberately forcing or coercing self-destruction and that others may advance personal motives by aiding in suicide (Adams, et. al., p. 2031); that when the entire medical profession is involved in euthanasia, including the poorly trained, the insensitive, the less skilled, there becomes the danger that physicians might not do whatever they can to avoid euthanasia if possible (Newman, p. 177); and that some people who enjoy the exercise of power over others might become addicted to the process (Doerflinger, p. 19). It is this fear of abuse that leads the AMAs Council on Ethical and Judicial Affairs to argue that the ban on active euthanasia is a bright line distinction that deters this type of potential abuse. They state: Allowing physicians to perform euthanasia for a limited group of patients who may truly benefit from it will present difficult line-drawing problems for medicine and society. In specific cases it may be hard to distinguish which cases fit the criteria established for euthanasia. For example, if the existence of unbearable pain and suffering was a criterion for euthanasia, the definition of unbea rable pain and suffering could be subject to different interpretations, which might lead to abuse of the process in the case of certain practitioners. (CEJA, p. 2232). Proponents of euthanasia argue that the risk of abuse, while certainly present, is not really much of a threat. This is true first, because laws against homicide are severe enough to provide a strong deterrent (Newman, p. 178); second, because a clear set of guidelines prescribing when active euthanasia is allowed will prevent confusion (Adams, et. al., Gifford); third, because we already risk the practice of abuse by allowing passive euthanasia, and such abuse has not occurred (Newman, p. 178); and finally, that the current state of illegality promotes an absence of discussion and actually encourages the practice of clandestine euthanasia (Newman, p. 177). As Gifford (p. 1572) succinctly puts it, what slope could be more slippery than one with no guardrails whatsoever? Additionally, the balancing tests already in place by the legal system should serve to eliminate this problem. Adams, et. al., (p. 2034) explain: For example, some opponents of physician-assisted suicide argue that pe rmitting some assisted suicides may lead to the killing of patients who want to live. This slippery slope argument expresses a utilitarian rationale for prohibiting suicide assistance. Others argue that suicide and the assistance of suicide is intrinsically evil, and that sanctioning them will damage the fabric of social morality. These and other utilitarian and moral considerations are encompassed within the states interest in preserving the sanctity of all life and affect its weight in the balance against the patients interest in self-determination. Opponents of euthanasia contend that there is no guarantee that euthanasia will be strictly voluntary. The potential for sub Arguments For and Against Euthanasia Arguments For and Against Euthanasia Euthanasia: Whose decision is it I. Introduction In a 1988 issue of the Journal of the American Medical Association, an article titled Its Over Debbie describes how an anonymous doctor administers a fatal dose of morphine to a woman dying of ovarian cancer (Anonymous, 1988). In a 1989 issue of the New England Journal of Medicine, ten doctors associated with the nations leading hospitals and medical schools declare their belief that it is not immoral for a physician to assist in the rational suicide of a terminally ill person (Wanzer, et. al., 1989). In 1991, the New England Journal of Medicine published a detailed account written by Dr. Timothy Quill which discussed his decision to help a patient suffering from leukemia commit suicide (Quill, 1991). In 1990, Dr. Jack Kervorkian uses his suicide machine to help a woman suffering from Alzheimers disease, one Janet Adkins, end her life in the back of a Volkswagen bus (Risen, 1990). Janet was the first of twenty patients who have been aided by Kervorkian in the past three years. He rem ains committed to his practice. In 1991 the Hemlock Society publishes a how-to manual on committing suicide. Entitled Final Exit, it zooms to the top of the national best seller lists and stays there for several weeks (Altman, 1991). Each of these events has served to provoke ever widening media coverage of the issues surrounding euthanasia and physician assisted suicide, and a national debate has arisen around these practices. This debate is not merely limited to attorneys and physicians. Suddenly, these issues and this debate are now a part of life in mainstream America, and many Americans face dilemmas that did not exist in simpler times; dilemmas that many would rather not have to face. II. Review of the Literature a. Euthanasia: The Nature of the Debate It is this sudden change in the way Americans are dealing with death, the nature and scope of the debate about dying, which prompts this analysis of the issues surrounding euthanasia. This debate is largely a debate about what is ethical. Questions the debate attempts to answer include: Is it right to commit suicide? Is it ethical for someone else to help? Is it right to put others to death at their own request or at the request of family members? These questions are important because they help to define our society and our culture. The way people deal with and respond to issues of life, ritual, and death serves to shape the nature of our society. This is why society must attempt to decide what is right; what is ethical conduct for the various actors in our communities when we face death. There are several reasons why this debate has surfaced in the 1980s. Death is nothing new, it has existed for thousands of years. Each culture has developed its own rituals and mechanisms for dealin g with death. These mechanisms serve to provide solace, a sense of continuity, and allow the culture to continue even as the members of the community cannot. However, our own culture has experienced many shattering changes that have altered the nature of dying. Suddenly we are forced to rethink the issue of death and we must decide what types of behavior are ethical when someone is dying. Before we can examine the debate about the ethics of dying, we must examine why the debate exists. Perhaps the main reason that death has changed in western culture has to do with advances in medicine and technology. Many of the diseases that have historically killed people are now no longer a threat to most individuals. Medicine has made a variety of advances in the treatment of diseases such as smallpox, tuberculosis, malaria, pneumonia, polio, influenza, and measles. People now rarely die of such traditional causes. Life expectancy has risen to almost 75 years in the United States. The quality o f life has also changed fundamentally during the past 100 years. Not only does almost everyone in the United States have enough to eat, but people eat higher on the food chain. There is a great deal more meat and animal fat in modern diets. Just these differences alone have changed death significantly. People now develop heart disease, adult onset diabetes, cancers, and AIDS. These types of diseases are more the result of lifestyle than bacteria. With these new diseases, suffering is often more prolonged and treatment is frequently quite painful. Also, as people are living longer, the diseases of the aged have become increasingly prevalent. Many more people now suffer from problems like senile dementia and Alzheimers disease. These diseases ruin the mind while preserving the body, allowing life to continue long after any quality that the life might have is gone. If what we die of has changed, perhaps the way that we die has changed even more. Throughout history, death has been a family affair. People usually died in the home after a short bout with an illness or as the result of an accident. Today, increasingly, death occurs in an institutional setting such as a convalescent home or a hospital, after a variety of technologies are applied in an attempt to prolong the life of the sick person. Often these technologies can be quite effective. People can now live for months and even years attached to a variety of tubes and technol ogies. About 75% of all deaths in 1987 occurred in hospitals and long term care facilities, up from 50% in 1950 . . . The Office of Technology Assessment Task Force estimated in 1988 that 3775 to 6575 persons were dependent on mechanical ventilation and 1,404,500 persons were receiving artificial nutritional support. This growing capability to forestall death has contributed to the increased attention to medical decisions near the end of life. (CEJA, 1992, p. 2229) People realize that the chances of facing the institutionalization of death increase daily, and they feel a profound lack of control. Surveys have consistently indicated that a large majority of people in the United States would like to be allowed to end their lives before incurable and painful diseases finally kill them (CEJA, p. 2229). Because of the changes that have impacted death, with regard to both how and where we die, the debate about how we should be allowed to die has been renewed. This paper will examine the s everal facets of this debate. It will define the terms that are relevant to the debate, examine the legal state of euthanasia today, discuss the ethics of euthanasia by examining arguments made by proponents and opponents of euthanasia, and by applying several Normative Ethical Theories to the issue. Finally, it will explore the power implications that infuse the debate on euthanasia and present arguments in favor of moving toward a care based ethic of dying and away from the current rights based ethic. b. Definitions If we are to effectively understand the debate about the right to die in the United States, it is imperative that a few basic terms be understood. The first and most important term is euthanasia. Originating from the Greek terms eu (happy or good) and thanatos (death), euthanasia means literally happy death or good death. The American Medical Associations Council on Ethical and Judicial Affairs defines the term as follows: Euthanasia is commonly defined as the act of bringing about the death of a hopelessly ill and suffering person in a relatively quick and painless way for reasons of mercy. In this report, the term euthanasia will signify the medical administration of a lethal agent to a patient for the purpose of relieving the patients intolerable and incurable suffering. (p. 2230) Other sources have defined euthanasia variously: The act or practice of painlessly putting to death persons suffering from incurable conditions of diseases. (Wolhandler, 1984, p. 363), . . . to refuse un wanted medical treatment or to have ongoing care withdrawn even though the patient will die if treatment is terminated. (Adams, et. al., 1992, p. 2021). Euthanasia is a general term that can actually mean a variety of different things depending upon the context in which it is used. For this reason, a number of supporting terms has become the convention when discussing euthanasia. These terms help to narrow the subject matter and distinguish between different types of euthanasia. The important terms that help to subdivide and classify euthanasia by type are voluntary/involuntary and active/passive. Voluntary euthanasia is a death performed by another with the consent of the person being killed. This consent may be in writing as in the case of a living will or advance directive. Involuntary euthanasia is a death performed by another without the consent of the person being killed. The AMAs Council on Ethical and Judicial Affairs makes three distinctions concerning consent and euthanasia: Voluntary euthanasia is euthanasia that is provided to a competent person on his or her informed request. Non-voluntary euthanasia is the provision of euthanasia to an incompetent person according to a surrogates decision. Involuntary euthanasia is euthanasia performed without a c ompetent persons consent.(p. 2230) Wolhandler compares the terms in a different context.Those who condemn euthanasia of both kinds would call the involuntary form murder and the voluntary form a compounded crime of murder and suicide if administered by the physician, and suicide alone if administered by the patient himself. As far as voluntary euthanasia goes, it is impossible to separate it from suicide as a moral category; it is, indeed, a form of suicide. Voluntary euthanasia may involve participation of second parties. (p. 366) The distinction between active and passive euthanasia is not nearly as clear as the previous distinction. Although many authors claim that the difference between the two types cannot be identified or is irrelevant at best, much of the debate on the subject is over this distinction and most of the current legal issues turn on this distinction. While this paper will contend that the difference between the two should not be recognized, it is both useful and important to know where the line is drawn. The AMA, which is strongly opposed to active euthanasia, has seen fit to endorse passive euthanasia in appropriate situations. The Council on Ethical and Judicial Affairs makes the distinction as follows: The physician is obligated only to offer sound medical treatment and to refrain from providing treatments that are detrimental, on balance, to the patients well being. When a physician withholds or withdraws a treatment on the request of a patient, he or she has fulfilled the obligation to offer sound treatment to the patient. The obligation to offer treatment does not include an obligation to impose treatment on an unwilling patient. In addition, the physician is not providing a harmful treatment. Withdrawing or withholding is not a treatment, but the foregoing of a treatment. (p. 2231) According to Wolhandler, (p. 367) it is t he nature of the acts performed by the second party that distinguishes between active and passive euthanasia. The courts have held that acts of omission (removal of respiratory assistance, hydration, and feeding tubes) are allowable behavior. Although unplugging a respirator and switching off a dialysis machine are arguably acts of commission, an increasing number of judges and commentators have accepted these acts as permissible passive euthanasia in both voluntary and involuntary settings. Gifford (1993) describes the difference between the two types of euthanasia this way: Passive euthanasia involves allowing a patient to die by removing her from artificial life support systems such as respirators and feeding tubes or simply discontinuing medical treatments necessary to sustain life. Active euthanasia, by contrast, involves positive steps to end the life of a patient, typically by lethal injectiond (p. 1546) The right to passive euthanasia has also been termed the right to die by some authors (Adams, et. al., p. 2021-22). With an understanding of the different types of euthanasia, we can now define some other key terms. It is important to understand how physician assisted suicide differs from euthanasia, and it is also necessary to define the terms advance directive and competence since they are crucial in determining the difference between voluntary and involuntary euthanasia. The term physician assisted suicide is somewhat self-explanatory. It occurs when a physician provides aid to a patient so they can commit suicide. However, it is also necessary to see the difference between this type of action and euthanasia. The AMAs Council on Ethical and Judicial Affairs states that Euthanasia and assisted suicide differ in the degree of physician participation. Euthanasia entails a physician performing the immediate life ending action (e.g., administering a lethal injection). Assisted suicide occurs when a physician facilitates a patients death by providing the necessary means and/or information to enable the patient to perform the life-ending act (e.g., the physician provides sleeping pills and information about the lethal dose, while aware that the patient may commit suicide). (p. 2231) It is important to realize that the difference between euthanasia and assisted suicide lies in the behavior of the physician. This difference in behavior has recently become a major legal battleground that will be explored in the following pages. The advance directive has recently become an important new device to aid the terminally ill. Many states have legalized the advance directive, partly in an attempt to avoid dealing with problems associated with active euthanasia, and partly to help ease the burdens on the dying and their families. Singer (1992) provides a good definition of advance directive and explains how it is used. An advance directive is a written document completed by a competent person that aims to guide medical treatment after the person becomes incompetent. There are two types: instruction directives, which focus on the types of life-sustaining treatment that the person would want under various clinical situations, and proxy directives, which focus on who the person would want to make health care decisions if the person were unable to do so. (p. 22) The advance directive is useful because it can theoretically eliminate the need for involuntary euthanasia. It ensures that a voluntary decision is made in advance, even if the individual could not make such a situation at a later date. If everyone made use of the advance directive, there would be no need to debate policy decisions that must be made in the case of an incompetent person on life support. Because advance directives have neither been accepted nor widely used by the general public, many of the problems that could potentially be solved remain. This situation caused right to die groups in both California and Washington to propose ballot initiatives that would legalize active euthanasia (Gifford, p. 1550-51). Although active euthanasia is not legal in any United States jurisdiction, passive euthanasia is generally allowed at the request of a competent individual. Because of this it is critical to understand what constitutes competence. Courts have defined legal competence as the mental ability to make a rational decision, which includes the ability to perceive, appreciate all the relevant facts, and to reach a rational judgement upon such facts. In the euthanasia context, legal competence is the incurable s ability to understand that in requesting active euthanasia he is choosing death over life. Only clear and convincing evidence should suffice for a finding of an incurables competence. (Wolhandler, p. 366-67) c. The Legal State of Euthanasia With a knowledge of the meaningful terms that will be involved, it is important to discuss the legal state of euthanasia in the United States today. As technology has placed more and more people on life sustaining devices in this country, the courts have had to deal with several cases that pertain to euthanasia in a variety of ways. This section of the paper is designed to review those cases briefly and to assess how the rulings in those cases have set the policy for the practice of euthanasia today. The courts first dealt with euthanasia in the Quinlan case in 1976. Karen Ann Quinlan lapsed into a coma after mixing a variety of pills and alcohol at a party. After it became apparent that she would not be revived, her parents went to court to have her respirator removed. The New Jersey Supreme Court ruled that her parents had the right to have the respirator removed and that Karen be allowed to die. Ironically, because her parents did not request removal of feeding and hydration tubes , she survived nine more years curled in a fetal position in a New Jersey rest home (Wolhandler, p. 366). In this case, the New Jersey court effectively sanctioned nonvoluntary passive euthanasia. The next prominent case was decided by the New York Supreme Court in Superintendent of Belchertown State School v. Saikewicz. Here the court found that a competent patient had the right to refuse medical treatment, allowing for a patient to decide in cases of voluntary passive euthanasia (Gifford, p. 1575-76). Later, in Satz v. Perlmutter, a Florida District Court of Appeals came to essentially the same conclusion (Wolhandler, p. 372-73). In Severns v. Wilmington Medical Center, the Delaware Supreme Court gave the husband of a comatose woman the right of guardianship and the authority to remove her respirator or withhold other treatment as he saw fit. In this case the court relied on previous decisions made in Quinlan, Saikewicz, and Satz for its finding (Wolhandler, p. 373). In Thor v. Su perior Court (California), the court granted the request to withhold treatment from a severely depressed quadriplegic only after a psychiatric evaluation determined that the request was based on poor quality of life and not just on severe depression (Pugliese, 1993, p. 1326). The courts have not restricted the right of passive euthanasia to just the terminally ill. Elizabeth Bouvia was a relatively young woman who suffered from severe cerebral palsy and attempted to starve herself to death in a California hospital by requesting the removal of a nasogastric feeding tube. She was denied this request because the hospital feared it would be party to suicide. The California court of appeals ordered the physicians to remove the tube and argued that she had the right to enlist the assistance of others in ending her life (Sprung, 1990, p. 2213). The courts have also found that doctors and hospitals must at least obtain consent from third parties that would have a significant interest in the patients outcome if the patient is incompetent. In the case of Helga Wanglie, a Minnesota court denied a hospital administrator permission to disconnect her respirator against the wishes of her husband (Gifford, p. 1571). In sum, these cases indicate an emerging consensus that courts will generally allow treatment to be withheld from patients who are terminally ill if it is in the best interests of the patient and at the request of patients or family members. It is this emerging consensus that made the U.S. Supreme Courts decision in the Cruzan case so interesting. In the only euthanasia case heard to date by the U.S. Supreme Court, the justices, in a 5-4 decision, allowed to stand the decision made by the Missouri Court of Appeals not to disconnect the life support apparatus from Nancy Cruzan (Cruzan v. Director, Missouri Dept. of Health, 1990). Although the court did find that a right to refuse treatment could be found in the Due Process clause of the Fourteenth Amendment, and did not prohibit the courts from looking in other areas for this right (Adams, et. al., p. 2025), it also upheld the right of the State of Missouri to require . . . clear and convincing evidence that Ms. Cruzan would have desired withdrawal of these treatments. (Newman, 1991, p. 175). In the realm of physician assisted suicide, only two major cases have been decided. In the case against Dr. Timothy Quill that arose because of the publication of his article in the New England Journal of Medicine, the grand jury for the state of New York refused to return an indictment (Bender, 1992, p. 524). In the more publicized case of Dr. Jack Kervorkian, the courts have not yet decided on the constitutionality of the Michigan law that bans physician-assisted suicide. Kervorkian is currently free on bond and continues to aid other patients who wish to commit suicide (Pugliese, p. 1300-05).(1) A brief assessment of the cases described above indicates that the courts have essentially legalized voluntary passive euthanasia, finding justification to refuse or have medical treatment withheld in the constitutional right to privacy, the common law right of self determination, or the more general concept of autonomy (Gifford, p. 1575-78). With regard to involuntary passive euthanasia, the courts are generally supportive of the practice, but they have the right to insist on a more stringent standard of evidence before approving such procedures. The courts have generally employed a balancing test that weighs the patients right to privacy and self-determination against the interest of the state in preserving life. The interests of potential third parties that might desire that the patient continue to live, and the ethical image of the medical profession (Adams, et. al., p. 2022). In cases of assisted suicide, some states have laws against the practice, the AMA forbids it, most juries are refusing to find the actors guilty, and the courts have yet to decide the question. Both voluntary and involuntary active euthanasia remain illegal. d. The Debate About Euthanasia The movement to legalize active euthanasia has existed for quite some time. Initially popularized in Britain during the 19th century, it gained some adherents in the United States during the 1920s. It was the Nazi program of active euthanasia in the 1930s and 4os that cast a pall of disrepute over the practice that remains today. The revival of this movement today can largely be attributed to the onset of the issues discussed at the beginning of this paper, and to the efforts of the Hemlock Society, a group of individuals that actively promotes the right to dignified death. The Hemlock Society recently promoted ballot initiatives in both Washington and California that would have legalized active euthanasia in those states (Gifford, 1993). This revival of the right to die movement has led to hotly contested debate about the practices of active euthanasia and physician assisted suicide. This paper will attempt to encapsulate this debate by presenting the arguments made by both opponents and supporters of these procedures. Since arguments made by both sides are used in cases of euthanasia and assisted suicide, the generic term euthanasia is used for simplicity to suggest the concept of aided death unless otherwise indicated. Those opposed to euthanasia and assisted suicide present a variety of arguments in support of a ban. e. The Case Against Euthanasia Euthanasia destroys societal respect for life. By becoming commonplace and used in medical practice along with more traditional methods of healing, society becomes desensitized toward death to the point where life is no longer valuable. This attitude serves to degrade humanity and leads to a variety of social ills. In a society that devalues life, people have no compunctions about committing violent crimes and murdering others. The overall quality of life becomes seriously undermined and society as a whole deteriorates (Doerflinger, 1989, p. 16-19, Koop, 1989, p. 2-3). Once euthanasia becomes legal, opponents contend, the potential for abuse at the hands of caregivers vastly increases. Closely related to this argument is the argument that those who enjoy the exercise of power over others might become intoxicated with it and actually come to enjoy killing. One step down the path toward euthanasia simply makes it that much easier in the future to take further steps. This argument is al so referred to as the wedge theory or the slippery slope. One of the most outspoken opponents of euthanasia, University of Michigan professor of law Yale Kamisar, has articulated a three pronged attack that utilizes the wedge theory, the risk of abuse, and the risk of mistake. The proponents of the wedge theory argue that Once society accepts that life can be terminated because of its diminished quality, there is no rational way to limit euthanasia and prevent its abuse. According to this theory, voluntary euthanasia is just the thin edge of a wedge that, once in place, will be driven deeply into our society. Kamisar concludes that legalized voluntary euthanasia inevitably would lead to legalized involuntary euthanasia because it is impossible to draw a rational distinction between those who seek to die because they are a burden to themselves and those whom society seeks to kill because they are a burden to others.(2) (Wolhandler, p. 377) Many who raise the wedge or slippery slope a rgument use the Nazi experience with euthanasia as an empirical example of this process in action. They argue that a public policy of murder inexorably follows from an initial, limited step, namely the adoption of a carefully defined euthanasia program, and that a program designed to get rid of those with lives unworthy of life quickly degenerated into the holocaust (Newman, p. 167). What follows is a description of the Nazi euthanasia program excerpted from Liftons (1986) book: National Socialist euthanasia or mercy death was a program of killing persons with unworthy lives. These persons were not moribund, and their families, with the rarest exceptions, wanted them to live. It was not a good death, as the word denotes, but a systematic program of killing without any mercy whatsoever . . . The program, referred to in the National Socialist bureaucracy as T4, was not based on any law, but was initiated by a secret order traceable to Hitler and his chief physician, Karl Brandt . Ment al hospitals were required to report all chronic schizophrenics, manic-depressives, mental defectives, epileptics, and later, debilitated old persons. A separate division, the Public Transport division for the Sick, took care of the collection and transport of such patients to institutions where they were put to death . Relatives received false death certificates and even letters of condolence . . . It is estimated that during two years of this program, ninety thousand persons went to their deaths. While this description of the Nazi euthanasia program is indeed chilling, it provides within it a devastating attack against using it as justification for the slippery slope argument. Proponents of euthanasia in the United States point out that the Nazi program was not one of euthanasia, but a program of mass murder disguised as euthanasia. Gifford (p. 1570) sums up the response of several authors by stating that The Nazis hid their racist, eugenic agenda behind the term euthanasia, termi nating in secret the lives of undesirables. It must never be forgotten that the Nazi euthanasia program was never euthanasia at all. That the Nazis co-opted the term for their own purposes should not obscure the fact that their motive was, from the very beginning, entirely different from that of todays euthanasia proponents. The current euthanasia movement is anything but covert. The Hemlock Society and other supporters of the right to receive aid in dying have spent millions of dollars to publicize their efforts. In this context, death is presented as a positive alternative to pain and suffering, not a utilitarian tool. Proponents of euthanasia also attempt to refute the slippery slope argument in a variety of other ways. They contend that the current mechanisms used by the courts could easily prevent any slide toward involuntary euthanasia,(3) that the current practice of passive euthanasia proves that the slope isnt all that slippery since we havent witnessed any massive killing programs, and that the example of how forced sterilization in the U.S. has diminished rather than increased, provides a more appropriate example to rely on. Even Callahan (1989), a vocal opponent of active euthanasia, admits that the Nazi experience is not particularly applicable to the U.S. experience and that Lives are not b eing shortened. They are steadily being lengthened, and particularly for those who are the most powerless: sick children and the very old, the mentally and mentally retarded, the disabled and the demented (p. 4). Newman (1991) also attacks the concept of the slippery slope itself. Arguing that just pointing out that one type of action could conceivably lead to another constitutes a very unpersuasive argument and that for the premise to hold true, it must be shown that pressure to allow further steps will be so strong that these steps will actually occur. He also reminds us that such arguments are frequently abused in legal and social policy debate (p. 169). Besides Kamisar, the risk of abuse argument has also been put forth by a host of other authors who variously claim that assisted suicides might result in flagrant murders that may be perpetrated by deliberately forcing or coercing self-destruction and that others may advance personal motives by aiding in suicide (Adams, et. al., p. 2031); that when the entire medical profession is involved in euthanasia, including the poorly trained, the insensitive, the less skilled, there becomes the danger that physicians might not do whatever they can to avoid euthanasia if possible (Newman, p. 177); and that some people who enjoy the exercise of power over others might become addicted to the process (Doerflinger, p. 19). It is this fear of abuse that leads the AMAs Council on Ethical and Judicial Affairs to argue that the ban on active euthanasia is a bright line distinction that deters this type of potential abuse. They state: Allowing physicians to perform euthanasia for a limited group of patients who may truly benefit from it will present difficult line-drawing problems for medicine and society. In specific cases it may be hard to distinguish which cases fit the criteria established for euthanasia. For example, if the existence of unbearable pain and suffering was a criterion for euthanasia, the definition of unbea rable pain and suffering could be subject to different interpretations, which might lead to abuse of the process in the case of certain practitioners. (CEJA, p. 2232). Proponents of euthanasia argue that the risk of abuse, while certainly present, is not really much of a threat. This is true first, because laws against homicide are severe enough to provide a strong deterrent (Newman, p. 178); second, because a clear set of guidelines prescribing when active euthanasia is allowed will prevent confusion (Adams, et. al., Gifford); third, because we already risk the practice of abuse by allowing passive euthanasia, and such abuse has not occurred (Newman, p. 178); and finally, that the current state of illegality promotes an absence of discussion and actually encourages the practice of clandestine euthanasia (Newman, p. 177). As Gifford (p. 1572) succinctly puts it, what slope could be more slippery than one with no guardrails whatsoever? Additionally, the balancing tests already in place by the legal system should serve to eliminate this problem. Adams, et. al., (p. 2034) explain: For example, some opponents of physician-assisted suicide argue that pe rmitting some assisted suicides may lead to the killing of patients who want to live. This slippery slope argument expresses a utilitarian rationale for prohibiting suicide assistance. Others argue that suicide and the assistance of suicide is intrinsically evil, and that sanctioning them will damage the fabric of social morality. These and other utilitarian and moral considerations are encompassed within the states interest in preserving the sanctity of all life and affect its weight in the balance against the patients interest in self-determination. Opponents of euthanasia contend that there is no guarantee that euthanasia will be strictly voluntary. The potential for sub