Medicine River

â€Å"Where We Belong† Thomas King’s book â€Å"Medicine River†, is about a man named Will, who no matter what he does, he feels his connections are not he wants when he lived in Toronto, that is, until he goes back home to Medicine River for his mother’s funeral. This is where he meets Harlen Bigbear, a blunt and straight-forward kind of guy who becomes one of Will’s best friends. I feel Harlen is a big reason why Will comes back to Medicine River.As much as Will and James, who is Will’s brother, had a mother growing up, I feel Will finally has a sense of family when he goes back to Medicine River. A day out with everyone in town seems to make Will a part of their own. Will is in an intimate friendship with Louise Heavyman and plays the father figure to her infant daughter, South Wing. Harlen, I feel is a big part of Will coming back to Medicine River, Harlen was kind of aggressive on his approach to getting to know Will.Harlen tried to get to know Will. Harlen tried to spice up Medicine River, comparing it to Toronto. He even said that there were no Indian photographers, stating there was no competition for an Indian photographer. Harlen also said that it would be a good idea to â€Å"start [Will’s] own business† (King 90). I feel that if Harlen did not suggest he try, Will probably would have stayed in Toronto. Harlen did everything he could to bring everything Indian back home.

Article Review on Human Buyology

Human BUYology 101 Articles info: â€Å"Human BUYology 101† by Rachel Sullivan. Published in Reader Digest Asia, 2011; 42-49. The article, Human BUYology 101, argues that consumers tend to make unplanned purchased that cause by the psychological forces. The author tried to highlight what makes people buy. The article has many quotes from the book of BUYology by Martin Lindstrom. It first presents the arguments of those supporting the idea of the effectiveness of logos, product placement and subliminal advertising, the correlation between religion and branding, then the influence of culture and gender divide and lastly, the influence of sense.The first part of the article mainly focuses on the idea that the effectiveness of logos, product placement and subliminal advertising: how those factors can influence people to buy. We are constantly bombarded with subliminal advertising throughout our waking hours. For the most of us, the main source of this is television advertising. It starts with eye-catching logos which could last in our memory maybe like, forever. Then, product placement plays a large part in how easily and effectively subliminal advertising can happen.Besides that, the author of the article highlighted in the article with the opinion expressed by the correlation between religion and branding where shopping is the same way as we practice our religion. Consumers' perception of well-known brands just like their views on the figures associated with religious icons. In short, it can be concluded that this well-known brands can create obsessed within themselves. People want the feel to belong; sense of belonging. The author calls this as religious experience which is related to religious value in impulsive buying behavior among the consumer.The author also discuss about how the culture and gender divide could influence the unplanned purchase of some consumer. Culture may refer to the set of values, ideas, and attitudes that are accepted by a homoge nous group of people and transmitted to the next generation. Culture also determines what is acceptable with product advertising. Culture determines what people wear, eat, reside and travel. So, culture could affect the decision making style for purchase of a product.While genders divide is kind of the difference between women and men, especially as reflected in social, political, intellectual, cultural, or economic attainments or attitudes. The author argued that women value their possessions for emotional and relationship-oriented reasons, whereas men value their possessions for functional and instrumental reasons. As for the influence of the sense on unplanned purchase where the author highlighted the term of sensory shopping, in which the sensory shopping has to do with consumer’s perception.Though necessarily based on incomplete and unverified (or unreliable) information, perception is equated with reality for most practical purposes and guides human behaviour in general . The primary human senses consist of smell, taste, hearing, touch, and sight. So, sensory shopping related to sensation or the physical senses like the smell of freshly baked waffles; transmitted or perceived by the senses and triggering the hungry feeling.I believe the topic being discussed is very arguable, and just I believe how people could amaze himself to found out how they could influenced by many different things that make them purchase. People should learn to resist the urge to buy unnecessary items. I strongly believe that planning is the key to keeping impulse buying under control. You may find after more rational reflection that you don't need the item as much as you thought you did. We should make and believe those impulse purchases as challenging as possible.

Cultural Sensitivity Essay

Cultural sensitivity is vital to remember when any firm does any business in a foreign market. Certain strategies and procedures used in the United States may not translate the same way in other countries or have the same impact. Other areas in the world operate their businesses with different priorities and in different cultures so it is crucial to consider how these differences may affect how business is done. Ethical situations will inevitably arise when a firm begins operations in a new international market so it is best to be prepared to face such situations with character. Company A now feels ready to enter the Eastern Asia market to continue its plans to grow the company and its profits. Taiwan is the country chosen for the next international expansion and there are many things to consider before entering this market. After researching several Eastern Asia markets to globalize in Taiwan, a republic of China was chosen as the country to expand in because there is the potential to manufacture a large volume of their engine parts there while paying very little in labor costs. The absence of any organized trade union is also a factor because there will be little resistance offered from any form of union. With expansion to any new country or region there are always cross-cultural ethical differences to take into consideration since all countries or areas hold their own world-views, religions, politics, traditions etc. Expanding to Taiwan with obviously has an impact on both Company A and Taiwan itself. While labor costs in Taiwan are much cheaper than the United States Company A must act ethically with concern to culture of Taiwan and the people who the employ there. Some people in Taiwan are grateful for American expansion to their country because there are more jobs available but there are also currently many in Taiwan who look at the American expansion in their country as a negative. There is a major concern in both Taiwan and the US that many of the multinational corporations doing business in Taiwan are doing far  more that just operating a company there. Most believe that these multinational corporations have a significant influence on the political agenda’s of Taiwan w ho have the interest of their company in mind before that of the people of Taiwan. There is also major concern for the worsening of government regulation in Taiwan, as there appears that they are not protecting workers from any physical, mental or social risk in the workplace. Company A should also consider creating some form or insurance benefits package for its Taiwanese workers as this would go a long way in showing them that they are ethical, that they care about their workers, and that they respect the Taiwanese people. This all has an affect on company A because they must make a conscious effort protect their image and brand so that they can continue to grow their business within the US and worldwide. Company A must make ethical decisions towards their operations across the company and within Taiwan so that they are not branded as a company who is simply taking advantage of cheap labor in a foreign country. With the majority of Taiwan believing that workers are not protected and that multinational corporations are attempting to influence political issues, I t hink it would be wise for Company A to make massive effort towards showing the people in Taiwan that they will protect their workers and use any influence they hold to help improve government regulation and attempt to mutually benefit both the company and the people of Taiwan. Company A must also consider the traditions and general way of life for the Taiwanese people. For instance learning their foods, drinks, religious practices, and recreational activities and somehow blending them into the company culture may help workers feel more comfortable and trusting towards Company A. Taiwanese people drink a lot of tea and juice drinks with boba in them so maybe offering or selling those within the company property would be a good idea. Also Buddhism, Taoism, and Chinese folk religion are the common practices in Taiwan so perhaps offering a place of worship on company grounds would be a great gesture. As far as work hours are concerned, Taiwanese people are working similar business ours that Western countries typically will work so they are hard working people and are accustom to similar schedule to what the factory in the US would for Company A. The will also be critical adjustments needed to be made regarding Company A’s marketing strategies in Taiwan versus how they would typically market their products in the US. There are different consumers in Taiwan because of their dense population and their culture. Most Taiwanese people would not tend to purchase large trucks or vehicles that would necessitate the heavy duty parts that Company A manufactures so they must concentrate almost all of their marketing efforts around a specific group of Taiwanese consumer or business that utilizes larger vehicles on a consistent basis. Company must market their product mainly to businesses that use heavy-duty equipment in their operations and in industrial areas since the average Taiwanese consumer would not buy a large truck, as they are not sold in such large volumes as they are in the US. As far as marketing to consumers Company A’s focus should be on the wealthy people of Taiwan who can afford to operate and maintain larger vehicles. Company A should also reduce the price of their product to ac commodate for a smaller volume of sales on trucks in Taiwan and also to begin attracting new clients since they will be new to the area. This price reduction should be offset somewhat by the less expensive labor costs experienced in Taiwan. Cross-cultural communication is also important for Company A to build a strong relationship with its Taiwanese workers. The first barrier to communication is language. The primary language in Taiwan is Mandarin Chinese and while most Taiwanese businessmen do speak English, it would be a good idea for some representatives from Company to a learn some Mandarin Chinese to help with communication efforts. Company should also consider having some translators available to maintain clear communication as well. Taiwanese business is based mainly off of respect so it is important to meet fact-to-face whenever possible, include senior executives meetings whenever possible, direct presentations to the senior ranking person and also make sure to give and receive any gifts with both hands as a sign of respect, and always look people in the eyes. It is also very important to refrain from being too frank or outspoken because this will be viewed as disrespectful. Is it vital to keep these practices as well as learning other important cultural traditions when conducting business in Taiwan or with any Taiwanese people. As far as marketing is concerned, while in the US marketing can be based around creativity and branding, it is important in Taiwan to focus  their marketing around integrity and respect. Taiwanese people and their businesses are less concerned with gimmicks and flash and maintain an emphasis on ethics and as always respect is absolutely vital. There will without a doubt be many cultural differences to overcome when opening a new plant in Taiwan. Marketing strategies and how businesses are viewed will not be the same in Taiwan as they are in the US so while A Company may be accustomed to operating their plants at home in a certain way, they must make adjustments to accommodate for the cultural variances of the environment their new plant is operating in. The impact that the cultural differences will have could be minor or they could be significant depending on how well Company A does their research and how they handle adapting their new plant to conform to the Taiwanese market while maintaining efficiency and their core company beliefs. Taiwan is densely populated country and their consumers purchase mainly small fuel efficient vehicles and since Company A specializes in engine components for heavy duty trucks they must focus their marketing strategies on smaller sized trucks with an emphasis on the advantages of their engi ne components, along with businesses that utilize heavy duty trucks in their operations.

Argument research paper Essay Example | Topics and Well Written Essays - 1000 words - 2

Argument research paper - Essay Example This is harmful for teenagers in many ways as it obscures their vision of reality and social relations as they exist. According to Danielle Dai and Amanda Fry, the average teenager spends around fourteen hours a week playing video games. They argue that this takes away time that could be used for studies and for developing their social skills (n.p.). The time that teenagers spend on video games does in fact, reduce the amount of time that they would be able to devote to their studies at an age which is crucial in deciding which school they would be able to attend. It therefore, influences teenagers for the rest of their lives in very significant ways. This time, even if it is spent playing video games together with friends, would not be able to create social bonds as the game occurs not at the level of reality but at a virtual plane. This would mean that the kind of social bonds that are created during outdoor games are all but lost while teenagers are engaged in such an activity. Such bonds would have the power to influence the teenager in the direction that the rest of his or her life is to take. In other words, teenage years are very crucial in the life of a person and should not be squandered with video games. On the other hand, researchers have also suggested that video games have in certain elements in common with traditional games that would fulfill the functions that traditional games are expected to play. The child would develop, according to these researchers, an ability to communicate and engage with peers at a social level. They have gone on to also argue that video games may not have any effect at all on the cognitive development of a child or teenager (Shapiro n.p.). This, however, makes the argument a tenuous one, at best. The kind of social skills that may develop as far as the teenagers are concerned would aid them only in the virtual world that is created by the video game. This world

Wind and Solar Energy Essay Example | Topics and Well Written Essays - 250 words

Wind and Solar Energy - Essay Example Hence, they both need a storage mechanism to store the excess power obtained when the wind and the sun are available. Usually, the storage mechanism is a battery system, like the lithium-ion batteries. Nevertheless, differences exist between these two energy sources. Availability of the two power sources brings about a difference between them. The difference is that, solar power is only available during the day. On the other hand, wind power can be available throughout the day for as long as he wind is blowing. The methods of obtaining the two also differs in that; wind power is obtained mechanically with the aid of turbines while solar power is obtained through solar panels that convert sunlight to electricity. The differences and similarities given show that, renewable energy is feasible and it can be used to build green economies worldwide. It provides man with diverse means to obtain energy. The two renewable energy sources complement each other and can be used to provide energy in diverse weather

Journal Assignment Example | Topics and Well Written Essays - 500 words - 12

Journal - Assignment Example nducted by three institutions jointly, namely New Buildings Institute, Skanska-Sweden and International Living Future Institute is intended at acting as an eye opener to the District taking into consideration its findings and recommendations. Largely, the District’s official perceives the report as essential in the sense that it would greatly enable them to achieve their policy goals based on the study’s presented framework; thus, attain the slashing of the rate of energy used by the District to half of its 2010 consumption in 2032. Subsequently, the study’s report is targeted at enabling the District to obtain data that it can use to back up its green technology projects, starting with the reduction of energy use. According to Bill Updike, who is a specialist in green building in the District Department of the Environment, the District’s history in relation to the uptake of progressive policies in green building has been outstanding and with the new report, the District’s efforts will be aided further in the advancement of the building industry to curtail more invigorating and irrepressible structures. This takes into consideration the key findings of the study that are as described herein. First, the District can be able to make energy consumption savings in new developments it has by about 60% based on the added initial cost of construction by about 1 to 3 percent. Second, there is an increase in the percentage of energy’s efficiency return on investment from about 6% to 12%. This figure may be deemed to rise further to between 33% - 36% should the net-zero energy be modeled through the use of solar power. Third, the study suggests the adoption of advanced measures in the conservation of water with the aim of reducing the consumption of the same and the amount that is lost in storm water runoffs from buildings in the District by about 1% to 3%. Subsequently, the study seeks at enhancing a return on investment rate by 5% to 10% through a further

Chronic Condition Essay Example | Topics and Well Written Essays - 2250 words

Chronic Condition - Essay Example ferrals the patient needs. The goals of this are established to ensure a thorough assessment of chronic diseases and their impact on patient’s physiology, as well as their psychology. Body End-stage renal disease, according to Patel (2009) is the â€Å"complete, or almost complete, failure of the kidneys to function. The kidneys can no longer remove wastes, concentrate urine, and regulate many other important body functions†. This disease can come about when the kidneys are no longer able to carry out their normal function. It is often seen with the kidneys functioning at less than 10% of normal functions (Patel, 2009). This disease is known to worsen within 10-20 years, before reaching end-stage levels. Patients at this stage require dialysis or a kidney transplant. Mostly, this disease is caused by diabetes and hypertension. In end-stage renal disease, the urine volume may decrease or may even stop, and patients afflicted with this disease require tests to assess the levels of the following: potassium, sodium, albumin, phosphorous, calcium, cholesterol, magnesium, complete blood count, and electrolytes (Patel, 2009). These tests would help establish the general condition of the patient and establish the necessary remedies which must be undertaken to ensure adequate care. Experience of your patient compared with the typical lived experience of those with this condition Donna, 37 years old, was first admitted two years prior to her current admission, with complaints of insomnia and frequent headaches. She expressed that she often woke up in the middle of the night and had trouble getting back to sleep soon after. She also experienced increasing bouts of headaches which could not be relieved by pain relievers. She also described feeling generally weak and easily exhausted. She also complained of hiccupping frequently, sometimes burping frequently, even when she has not eaten anything. Her husband also noted that she seemed to be darker as compared to before when she had lighter skin. She then sought consult with her GP who ordered some initial tests including blood work and urinalysis. Her initial results, prompted more tests to be undertaken until repeated confirmatory tests indicated that she had high creatinine levels which strongly indicated a diagnosis of chronic kidney disease. She was later admitted for AV Fistula (AVF) surgery in preparation for her dialysis. A month after her AVF, she was scheduled for dialysis. A kidney transplant was also recommended for her. Initial cross-matching tests from immediate relatives revealed no organ matches. In the meantime, her name was entered in the waiting list for patients needing new kidneys. Meanwhile, she was required to have weekly injections of erythropoietin, as well as daily medications for a variety of drugs which are meant to manage her potassium, sodium, as well as blood pressure. After one year from her initial consultation, her creatinine levels increased to levels re quiring dialysis.

DNA Sequencing Essay Example | Topics and Well Written Essays - 4000 words

DNA Sequencing - Essay Example The Sanger methods are able to sequence best from 30-350 nucleotides and therefore genomic sequencing strategies have been developed to sequence longer DNA of interest such as the gene of interest in this plant. In the shotgun sequencing strategies, DNA often of large size is shredded into smaller fragments that can then be sequenced individually. Shredding of the DNA is done by restriction enzymes or mechanically by shearing the DNA. The sequences of these fragments are then reassembled into their original order based on overlaps. Alignment of the sequences is done by a computer program to yield the complete sequence. In Whole-genome shortgun, the DNA is obtained without prior physical map knowledge and indiscriminately sheared into fragments of 100kb which are then cloned into plasmids and transformed. The DNA inserts obtained from the plasmids are sequenced individually and consequently assembled into a long contiguous sequence. The strategy has limits due to gaps which arise duri ng assembly due to the repeats in the sequences. Another strategy is primer walking which tends to deal with whole shortgun sequencing challenges in the assembly of â€Å"gaps†. Clones carrying inserts for sequences for both sides of the gap are identified and the DNA is sequenced normally. Resultant sequence is used to design a primer downstream from the former primer position. Pairwise-end sequencing is another strategy for genome sequencing which is performed on both sides of DNA of interest as opposed to one in whole-genome shortgun.... Usually alignment of the sequences is done by a computer program to yield the complete sequence. In Whole-genome shortgun, the DNA is obtained without prior physical map knowledge and indiscriminately sheared into fragments of 100kb which are then cloned into plasmids and transformed. The DNA inserts obtained from the plasmids are sequenced individually and consequently assembled into a long contiguous sequence. The strategy has limits due to gaps which arise during assembly due to the repeats in the sequences. Another strategy is primer walking which tends to deal with whole shortgun sequencing challenges in assembly of â€Å"gaps†. . Clones carrying inserts for sequences for both sides of the gap are identified and the DNA is sequenced normally. Resultant sequence is used to design a primer downstream from the former primer position. These steps are repeated over and over until the complete sequence of the insert is elucidated. Pairwise-end sequencing (double-barrel shortgun ) is another strategy for genome sequencing which is performed on both sides of DNA of interest as opposed to one in whole-genome shortgun. It reduces â€Å"gaps† thereby minimizing assembly errors which are common in whole-gun sequencing. However it poses a huge computational challenge during assembly. DNA is shredded into 150mb fragments and inserted into BACs in hierarchical shortgun sequencing strategy. Inserts are mapped into a physical map and organized by known location â€Å"Golden Tiling Path†. Inserts are fragmented further and cloned into plasmid where they are again recovered and sequenced according to â€Å"the Golden Tiling Path†. This strategy is applied for long pieces of DNA such as whole genome or chromosome and in

PROGRAMMING AND CULTURE IN ARCHITECTURE WAY Research Paper - 1

PROGRAMMING AND CULTURE IN ARCHITECTURE WAY - Research Paper Example This research paper will try to examine what people do and how their activities relate with one another. Similarly, researchers engage in observing the physical behaviors of people to generate data about their activities and the kind of relationships that sustained them. According to Gibson (2009), the researcher will try to understand about the misuse of places, and rules governing their behaviors. Additionally, the behavioral opportunities and obstacles that the environment might provide are also, observed. As a researcher, I will use both direct and dynamic methods to observe the behaviors of people in Guatemalteca Bakery restaurant. In research, the direct method will involve examining how the people in the environment follow or break the rules. On the other hand, the dynamic method will involve examining the activities of the people, the changes taking place and how the activities affect others. When a person wants to carry out research on the behaviors of people in a particular environment, certain factors must be considered. Therefore, the behaviors of people can be described in terms of the following concepts: actor, act, significant others and their relationships The actor who is the element of behavioral observation can be described depending on the intention of the descriptions. Individuals can be described with their social status, profession, age, and marital status. Guatemalteca Bakery restaurant consist of employees and customers of different status. We have the position of the manager, supervisors, coordinators and the subordinate staff. However, the customers also, possess different status as far as their professions are concerned. In this research paper, the actors are the employees who provide services to the customers. Guatemalteca Bakery restaurant has dressing code which the entire staff adhere to. Therefore, a staff member in this restaurant can be identified and differentiated from the customers because they wear uniforms. Similarly,

Avon Products Case Study Example | Topics and Well Written Essays - 1250 words

Avon Products - Case Study Example The company faced a challenge of flattening revenues and even declining operating income. There were many factors that led to this decline, one of the issues was that the company had grown at a faster proportion than the infrastructure and talent could hold. This called for an immediate intervention to save the company from collapsing. The current CEO who was known as Jung and the executive team launched a basic restructuring of the organization in starting of 2006 (Effron, 2009). Question two Leaning and transparency model was one that was targeted to bring change in the organization. For an organization to bring in change, one of the ways to ensure that change does not impact negatively to the organization is through training of employees. By doing so, employees are able to learn new tactics to use in order to integrate with the new change. In addition, employees are able to acquire skills to enable them to cope with the new requirements of the change. The company investment in exe cutive talent is one way of implementing learning model. The company planned to refurnish new talents as a way of ensuring that the company keeps up with the latest growth of the company. The employee’s new knowledge was also to be used as a model of ensuring that they are able to sustain the current growth of the company. ... The company aim to transform the organization through establishing bodies that would oversee transparency process is another example that assisted me to identify the model. The company aim of changing the top management behavior through teaching them on how to maintain a good image of the company is an aspect that is in learning and transformation model. The company also went ahead to recognize every personnel behavior as critical to the overall success of the business. These transformations were supported by performance reviews that were aimed at keeping an eye on the individual performance (Harris, & Hartman 2001). Question three One of the evaluation information that was obtained is that there is a need to create an efficient communication channel which will ensure that organizations processes are carried out in an efficient manner (Zofi, (2011). Communication plays a great role in tackling problems that might affect the organization. Efficient communication also ensures that ther e is a good relationship between leaders and their subordinates. In addition, communication plays a great role in enabling the organization to solve any issue that might affect the organization performance. This evaluation problem was to ensure that poor communication was eradicated and leaders implement policies that would enable the top management and low ranked employees to communicate frequently an aspect that would positively impact on the performance of the employees. Lastly communication would enable leaders to assess the talent of their employees. This is an important move in ensuring that categorization of talents in the organization is done appropriately (Harris, & Hartman 2001).

Close Reading or Literary Analysis Essay Example | Topics and Well Written Essays - 1250 words

Close Reading or Literary Analysis - Essay Example As an apostrophe, Donne is addressing an anthropomorphized Death and informs the character that it is not as powerful as some people make it out to be. The poem â€Å"demonstrates the impotence and the self-destructiveness of the antagonist† (Tromly 391). Donne begins the poem by directly addressing death, â€Å"Death be not proud,† and then admitting that some people might hold death in a revered place: â€Å"though some have called thee/ Mighty and dreadful† (1-2). Obviously, it is rather banal to have to point out the fact that the single event that all people that are alive cannot deter is that they will all die. There are no exceptions to this, and this is one of the few truisms that goes without anybody being able to form an argument against it. Considering this, the position that death is a powerful figure that is deserving of fear and respect seems like a difficult position to try to argue against. Of course, this would not have been a memorable or interesting poem if it had merely stated this obvious fact. The paradox that Donne creates is what makes this poem so well known. After informing death that it had nothing to be proud of, Donne then informs the character why this is the case: â€Å"For those, whom thou thinks’t, thou dost overthrow,/ Die not, poore death, nor yet canst thou kill me† (3-4). As Donne states, the people that death thinks it has killed were not actually killed by death. Beyond this, death also does not have the ability to kill the poet as well. Considering that the poet has been dead for centuries, Donne is obviously going to have to thoroughly explain why exactly this is true. Donne then begins to explain his reasons. First he states that death is not much difference in appearance from taking a nap: â€Å"From rest and sleepe, which but thy pictures bee,/ Much pleasure, then from thee, much more must flow† (5-6). Following the reasoning that resting or sleeping reinvigorates people and make them more able to enjoy

Following Approaches to the Study of Politics Essay Example for Free

Following Approaches to the Study of Politics Essay An approach is to deal with a situation or problem in a particular way. It is also the means by which something is reached. It is the angel form which one views political problems. It is a criteria for searching for the questions to ask. A criteria used to analyze political data. It can be implicit or explicit in what it explains. Some reasons why approaches are used in the study of political science is because it helps us to be more analytical and also helps suggest hypothetical relationships among political forces. The historical approach deals with political thinkers such as Machiavelli, Vico, Montesquieu, Savigny, Maine, Seeley and Freeman. It lays emphasis on the use of historical evidence for proper study of political situations. The reason for the use of this approach is that all political institutions have a long record of their rise and growth and their present form may be well understood in context of their history. This approach does not only explain the past but also enables us to draw dependable conclusions and also it provides us with basic principles for interpreting the future. Some strengths of this approach are that the value of historical approach enables us to make sound generalizations and we may also call them authentic by virtue because they are based on past evidence. Secondly the historical approach is always open to verification. Since it is based on gathered facts of history we may test the validity of conflicting ideas if needed. Lastly it gives us a sense of history than warns us against repeating blunders of the past. History becomes a lesson for the present generation .It enlarges our mental horizon, improves the perspective and builds up an attitude towards events. Some scholars have listed some problems facing the historical approach to the study of political science. Some of these scholars are James Bryce. He says the historical approach is often loaded with superficial resemblance. As such historical parallels may sometimes be illuminating, but they are also misleading in most of the cases. Also Sidgwick mentioned that political science is to determine what ought to be so far as the constitution and action of the government are concerned and this end cannot be discovered by a historical study of the form and functions of government.  The sociological approach emphasizes that social context is necessary for the understanding and explanation of political behavior of the members of a community. The sociological approach deals with the traits of individuals that are transmitted from one generation to another generation. It also deals with the culture of the people. Some strengths of this approach are that it cannot be criticized for being narrow because it is because it is a very broad approach. Due to its broad nature it cannot be ignored during empirical study. A weakness of this approach is that it is feared by most political analysts that it may convert politics to a branch of sociology. Psychological approach is an approach that came into being when political science moved close to the discipline of psychology. This was done in modern times by Graham, Wallas, Charles Merrian, Harrold Lasswell and Robert Dahl. It is the study of political science made by political writers in a way so as to deal with the role of emotions, habits, sentiments, instincts and ego that constitute essential elements of human personality. A strength of this approach is that it is the right approach enabling us to study politics with the help of psychological tool. It helps throw more light on political science. This approach is criticized as partially correct because it does not take into consideration some essential elements covered in some approaches. Secondly this approach deals with normative attributed in an empirical political theory that is it deals with b elief systems. The structural functionalist approach has proven to be very useful particularly in the comparison of political systems. This approach views political systems with the way they perform as a unit in its environment. However this approach has been criticized by Jean Blondel. He says that the approach does not enlighten one about the aims of the participants. Also he says before this approach can be effective it depends on what one accepts as a function, in view of this it is difficult to achieve complete objectivity. Even though Jean Blondel has criticized this approach it has some strengths ac an approach. This approach is quite attractive for comparative analysis of political systems this is because in most times it deals with the manageable collection of variables and produces a set of standardized categories that can be applied successfully to varied political systems. The greatest strength of this approach lies in the area of pattern maintenance of the system. The comparative approach seeks to show the similarities and  differences among political situations as a source to data of idea formation and classification. An importance of this approach is that in comparing and contrasting events, institutions, processes, experiences and expectations one gets clearer image of thing observed and shaper understanding of the meanings of the political systems being compared. A weakness of this approach is that problem with the comparative method is that research might be not objective and the researcher deliberately chooses countries to show negative or positive moments to proof his/her point of view. For example, let’s consider a hypothesis, that countries with weak trade unions are more economically successful than countries with strong trade unions. Here, trade unionists and, on opposite side, managing directors have a political point to make, so more than likely their conclusions might completely differ. So we should be aware that conclusions are not driven by someone’s motivations and values.

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