TO LIVE AND DIE IN A COMPASSIONATE COMMUNITY
At times, events which at first glance appear to touch only the individuals directly involved become, upon reflection, matters of deep significance to an entire society. The questions of euthanasia and assisted suicide, touching as they do on matters of suffering dignity, and freedom of our fellow citizens, certainly fall into this category. We struggle here with nothing less than the vision which will bind us to one another within the Canadian body politic. Given the importance which the Catholic community attaches to our common life, we cannot remain silent in the face of such critical issues. We enter this debate seeking to defend and to affirm the intrinsic value of human life; we also find the need to stress the nature of authentic freedom, the importance of the common life we share, and our ability to shape a future through our exercise of freedom, all of which also find a hallowed place both in Canadian history and in the Christian tradition.
Indeed, proposed changes to the laws which have held sway in Canada raise troubling questions for us, not only about the critical value of life, but also about the meaning of our life together as citizens of this country. We strongly oppose any legislative changes that would open the door to assisted suicide or euthanasia. We strongly affirm a call to a community rooted not in power, but in responsibility, not in pity, but in compassion. We call for that human dignity, which binds us to one another, especially in the face of social forces which separate us from one another. We do so reflecting not only on our Catholic values, but also upon the life of our nation, which is deeply rooted historically in a primacy of the community and a search for the good of all.
I. A community rooted in responsibility and compassion
The implication of an extension of rights which would be required by either the legalization or the decriminalization of euthanasia or assisted suicide trouble us for three reasons which directly relate to our relationship to one another and to society as a whole. We will deal firstly with the relationship between human rights and community, secondly with the distinction between freedom and control, and finally with the difference between pity and compassion.
A. Human rights in community
Allowing euthanasia and assisted suicide would radically isolate the person from society. The rights of the person, especially in terms of a commonly presumed "right to privacy", can set him or her apart from others, creating a society consisting only of a collection of individuals rather than one marked by mutual responsibility. The sense of the human person entailed in such a presentation would leave us with rights as the only framework within which to speak to each other.
In saying this, we do not seek to infringe upon the legitimate exercise of rights nor to subordinate persons to society. Rather, we seek to express our concern over the erosion of a long tradition of Canadian as distinct from American, political thought: namely that a viable and vibrant society constitutes the surest guarantee of the rights of the person. Unlike the American system. which founds its vision upon the primacy of "life, liberty, and the pursuit of happiness", all of which are read through the sovereign individual, we have within Canada sought to maintain and extend the blessings of liberty to all people through a common search for "peace, order, and good government". The 1960 Canadian Bill of Rights explicitly joined the defense of the dignity and worth of the human person and the family to "a society of free men [and women] and free institutions". We are not separated from one another but bound together in a common search for justice and freedom in community.
That intrinsic relationship between personal freedom and the vitality of our common life forms one of the hallmarks of the Christian tradition as well. Affirming the value of the person, who is made for life with others and finally with God, stands at the heart of our faith. Rights, for us, do not separate us from one another but bind us together in building a common life. We strongly oppose, therefore, the attempt to redefine human rights in an individualist way, since this would radically undermine Canada's ability to build a just society of which the critical tension between the common good and the good of the person is the keystone. Recent proposals for rewriting the legislation with respect to euthanasia and assisted suicide would further erode our sense of the common good, leading us to become a collection of competing interests.
B. Freedom and control
This raises for us a second issue: namely, the way in which the argument, as raised today, stresses the issue of control, or self-determination. This definition of the human person equates freedom with controlthe ability to dispose of the self in accord with a sovereign will. While we value highly the legitimate freedom and self-determination of the person, we cannot help but be deeply concerned about "control" becoming the dominant issue in the common discourse of our land subordinating all other goods, even life itself. We find such a concept of self-determination, which would ®ard broader issues of the common good or the good of the person, seriously problematic. A society which gives primacy to questions of control could ultimately become one which is fundamentally concerned with powerinitially over the self, but finally perhaps over others, even over their lives. Do we wish to redefine our common lives in such terms?
Much of the discussion on questions of euthanasia and assisted suicide makes use of precisely this form of discourse. The person's ability to engage others as agents in this control, or even to the ability of health care professionals to assume this right in the name of the person. As we shall note, this profoundly reshapes how we deal with one another. In a particular way this dramatically redefines the relationship between health-care professionals and patients.
Within the Christian tradition, and within the Western civilization which undergirds our political and social institutions, such dialogue has emerged only recently. Freedom, as distinct from the more narrowly focused debates on self-determination or control, has always found its roots in the desire for the good of the person, which would emerge not in isolation but in relationship. The sense of mutual interdependence and hence responsibility limited dramatically the powers of any agent.
It would be helpful to remember how the language of human rights emerged in our political traditions. The general concern was to defend persons in communities from the kind of arbitrary exercise of power which had marked a period of royal absolutism. Rights were meant to guarantee a vibrant and peaceful community by limiting such coercion or control. Ironically, the use of rights language to allow for euthanasia or assisted suicide would undermine the rights of our citizens by introducing questions of power and control over human life itself. Especially given the ways in which decisions would frequently lie in the hands of medical professionals or political decision-makers, such a context of power and control could easily change questions of life into matters of social or economic utility. Such power over so fundamental a human good as life itself would inevitably recast how we deal with one another in our society, from members of a free community to agents of control. That would drastically alter for the worse centuries of our political development.
C. Pity or compassion?
This leads us to a third major concern: namely, the way in which these issues reshape the question of compassion itself. We affirm the importance of a deep and abiding compassion, especially for those who are in the final stages of life. Such compassion, which should shape all our responses to those in need, must always exercise a primary claim on us.
The language of rights and self-determination frequently alters the meaning of compassionentering into and sharing the suffering of anotherto that of pityevincing sadness over the suffering of another who is left to bear the pain alone. While pity can grow into sympathy, alone it can leave us separated from others, distant, or outside their pain. How different this is from compassion, which involves entering into the pain of another, sharing his or her life. Here there is no isolation but only a deepening, and admittedly difficult, tie.
The questions raised by those who would change the current laws and practices emphasize this kind of distance between people, making the final resolution of the difficulties facing the person ultimately his or her private concern. In the process, suffering becomes a very private affair, one which isolates the dying patient. Current medical technology and practice only accentuate this isolation. Do we wish that distance and isolation to be the heart of our relations with one another?
Given our vision of an interdependent and mutually responsible society, a dialogue rooted only in pity strikes us as decidedly problematic. Especially in the face of the terrible tragedy of human suffering and the awesome challenge of dying, the Catholic community has felt a strong need to affirm the essential links between people and the social dimension of suffering, a reality too often overlooked in the current debate. This provides a deep link to our understanding of dignity in the face of the suffering and death.
We must remember that suffering, until recently, was part of the life of the community. Suffering both evoked the compassion of the community and, in the process, altered the community's activity and sense of itself, especially when it lacked the means for controlling the suffering. Today, suffering increasingly isolates us from one another and exaggerates a sense of distance and alienation. That makes us more and more likely to resort to questions of control for dealing with such issues.
While we must always be concerned with eliminating or at least diminishing physical pain and the other dimensions of human suffering, we must also involve ourselves compassionately in the lives of those who continue to suffer. Such compassion in dealing with the suffering of those facing death or protracted disease entails real responsibilities for us as a societyresponsibilities which require an appropriate allocation of resources. In this matter, the Church agrees strongly with the opinion of the Select Committee on Medical Ethics of the British House of Lords:
"<Despite the inevitable continuing restraints on health-care resources, the rejection of euthanasia as an option for the individual, in the interest of our wider social good, entails a compelling social responsibility to care adequately for those who are elderly, dying or disabled. Such a responsibility is costly to discharge, but is not one which we can afford to neglect">.
In the light of our Christian principles, and also of the tradition of the common good which is so important to the communitarian history of Canada, that sense of compassionate responsibility must stand at the heart of all our deliberations. Indeed, this discussion provides, we think, a critical time for reconsidering the allocation of social resources and our communal commitments as citizens to one another. To miss this moment and, in the process, to reinterpret compassion in an individualist manner would be to lose a critical aspect of our own historic identity and a possibility for shaping together a more compassionate future.
II. The human person in the shadow of death
In the light of the considerations we have just mentioned, we would like to look at the issues raised by proposed changes to the law on euthanasia and on assisted suicide. We do so as Catholics, rooted in a Gospel vision, but also as members of our society, seeking to preserve and extend those goods which make us distinct and free;
A. Life as relational
We noted above our concern for the ways in which "rights" language can isolate us from one another. Nowhere does this play a greater role than in questions dealing with human life. Very often, people are tempted to speak of life as a good possessed or one thing among others. Such a perspective informs much of the argument in favor of euthanasia or assisted suicide.
Fundamental to our response is a beliefwhich is deeply entrenched in both the Christian and legal traditionsthat life differs essentially from other human goods. This directly affects our "rights" over it. Within the Christian tradition, this essential difference arises from the divine origin of human life. We human beings serve as stewards not owners of what remains always a most precious gift.
"<Most people regard life as something sacred and hold that no one may dispose of it at will, but believers see in life something greater, namely a gift of God's love, which they are called upon to preserve and make fruitful">.
Life constitutes not one good among others, but rather a relational reality, a gift, certainly from God in the religious sense, but also from others in that we remain the recipients and givers of life. This will have profound implications for us when we return to the question of control over life. For the moment, we focus directly on the sacred quality of life, which was affirmed strongly in the majority decision in the Sue Rodriguez case.
Human life provides, then, the ultimate basis for all of our relationships, and indeed for justicethe quality of right relationships among persons. The justice of a society finds its measure in the society's ability to further and protect the lives of its members, given that life provides the basis for all other goods in society. For that reason, the legal, philosophical and religious traditions of the West have stressed defending life against any and all assaults. Philip Devine noted this in his study of philosophical and legal positions on death and killing:
"<Harm to society is not, I think, a distinct consideration. Society is made worse by wrongdoing within it, both directly and through the weakening of the force of its moral norms, and will suffer from loss of the services of at least some of its members. Again, there is something like collective grief, arising from the rupture of what may be called social friendship when one member is lost by death".>
When we deal with matters of life, we deal with the heart of our relationships, the place of the person in society and the bonds which link us together.
We affirm the special place which life occupies within our common discourse. This must be a fundamental point of departure for all subsequent debates especially given our concern for the common good of all in our community. To erode that sense of life as a gift we have in trust would undermine all efforts to build together a truly humane society.
B. Control or mutual responsibility?
The mutually interdependent nature of life flows from this idea of human life as relational. This undercuts the imagery of "control" which so often arises in our common dialogue, and consequently challenges attempts to establish some kind of power over life. Minimally, we know that the ability to have mastery over our lives finds an absolute barrier in the reality of death itself. At the same time, the maintenance of our lives, the very continuation of our existence, depends heavily upon the goodwill and support of others. The autonomy or sovereignty of the individual is radically challenged by that dependence.
This imposes, of course, a necessary sense of mutual responsibility. Both within the Catholic tradition and in the legal system, persons are called to exercise concern for others, whether directly through relationships or indirectly through groups or through structures of government. While we recognize that resources are limited, we also strongly affirm the responsibility of the community to its people, especially to those who are most vulnerable, including the ill. Indeed, so critical is this mutual responsibility that both the religious and legal traditions have affirmed the goodness of giving up one's life in defense of the other or out of love for God. Life is not so much an absolute good as a precondition for all other goods and rights.
This would tie in directly to the concern mentioned earlier about the limitations of privacy. While recognizing the rights and dignity of the person, we see the relational dimension of human life to be crucial as well. The right to life in particular calls not for the isolation of the person nor for a restriction of the responsibility of society but, if anything, for a reaffirmation of our mutual dependence and hence of a need for mutual concern.
That concept of life as ultimately lying beyond our control yet calling always for our care informs a key distinction for us: the distinction between killing and allowing to die, between natural death and induced death. We understand death as an integral part of life, over which we have no ultimate control. Today we have at our disposal vast arrays of technology capable of extending life in the face of death. Indeed, the attempts to control death often only extend the suffering of the patient. Recognizing the integrity of life, we must accept the limits on our ability to act. This represents part of a long-standing tradition within Catholic morality. It not only permits but affirms the appropriateness of decisions either to refuse or to cease certain treatment.
"<Even though we greatly value life, we do not consider physical life to be an absolute value that must be preserved at all costs. Death is not an evil nor a defeat but part of the human condition. Church teaching recognizes that death is 'unavoidable' and that without intending to hasten death, we 'should be able to accept it with full responsibility and dignity'.
"Medical treatment that is futile or extraordinary methods that only prolong the dying process are not required. The withholding or withdrawing of burdensome or disproportionate treatment is not assisted suicide or euthanasia. Allowing to die is not the same as making a person die. In addition, patients 'in the final phase of terminal illness may request and be given whatever analgesics are required to lessen their pain and suffering, even if such analgesics, though not intentionally, could shorten life'".>
We are called to recognize our limitations with respect to life and death. With Dr. John Scott, we note the limits inherent in human action:
"<Death is not the intended purpose of the withdrawal or withholding of treatment. Death would come with or without the therapy, and often the withdrawal has little effect on the timing of death. Our society believes the lie that modern medicine controls the quality and the timing of death and life. In reality we control very little. Our ability to resuscitate, prolong and cure is partial and transitory".>
Recognition of this limitation and a real humility before it remain a hallmark of the Catholic position.
In this regard, the Catholic tradition differs quite sharply from any position which would redefine this argument in a way which would give any person whether the patient or the medical professional or any other agentcontrol over life, as if matters of life and death were ultimately subordinate to our will. This includes suicide, assisted suicide and euthanasia. The assumption of ultimate control over the person would radically reshape the quality of our relationships with one another.
We see a rather dramatic extension of this idea in arguments which move the debate beyond issues of a "near death situation". The ability to exercise control over life would raise the logical question of what might constitute an "intolerable burden" or significantly degrade the quality of life of a person, leading him or her to request an assisted suicide or euthanasia. If control over life itself is admitted, other issues become a difference of degree, not of nature. How is one to guard against a person's desire to exercise this right due to chronic depression, isolation, or disability, for example? Granting a right, even if it is initially a circumscribed one, would necessarily lead to subsequent determinations, potentially of a eugenic form.
Granting such control was not the reason for removing the offense of attempted suicide from the Criminal Code. As Mr. Justice Sopinka noted in the Rodriguez case, "... the decriminalization of attempted suicide cannot be said to represent a consensus by Parliament or by Canadians in general that the autonomy of those wishing to kill themselves is paramount to the state interest in protecting the life of its citizens. Rather, the matter of suicide was seen to have its roots and its solutions in sciences outside the law and for that reason, not to mandate a legal remedy". In a 1986 report, the Law Reform Commission of Canada stated: "The decriminalization of attempted suicide, in 1973, did not have the effect of legitimizing suicide or of creating a true "right" to suicide in the classical sense of that word. The Commission feels that suicide remains an act which is fundamentally contrary to human nature".
In matters of euthanasia or assisted suicide, the will of another, be it the physician, a family member, or the guardian, plays an active role in causing death. One cannot simply assume the role of agent of the will of another, as if one's own will were uninvolved. At the very least, one is required to determine the competence of the other, to act as judge, or occasionally, in the case of euthanasia, to take the place of the patient who has lost the ability to reason. Because one is directly involved in the act in a manner necessary to the completion of the act, one becomes a formal co-operator in the act, not merely an agent of another. To assume that degree of control over the life of another person, especially at times when the person may not be able to exercise his or her reason, establishes a hegemony which at the very least creates serious ethical dilemmas.
The issue emerges in an important way in the words of physicians who deal on an ongoing basis with terminally ill patients. These physicians speak of the changed sense of relationship and identity which enters into the discussion once one accepts the kind of control over life which the decriminalization or the approval of euthanasia or assisted suicide would allow. Typical of such concerns is the following:
"<Apart from moral or ethical considerations, I don't know how any physician could risk performing euthanasia because of the potential damage to his or her future relationships with patients. I could imagine seeing a newly diagnosed cancer patient and being asked if I 'aid terminally ill patients in dying'....
"I believe that many patients would feel very ambivalent about being cared for by a doctor who performed euthanasia">.
Even those who advocate euthanasia in difficult circumstances note the ways in which the substitution of one's own will for that of the patient could become total:
"<But is it not true that once one accepts euthanasia or assisted suicide, the principle of universalizability forces one to accept termination of life without explicit request, at least in some circumstances, as well? In our view the answer to this question must be affirmative.">
The experience with euthanasia in the Netherlands raises disturbing questions about involuntary euthanasia, which increasingly is read in utilitarian terms. That would bode ill for a society committed to a defense of the person and of the common good.
Such issues have a particular urgency in our age given an aging population and diminishing medical and social resources. At what point does the possibility of choosing death become the responsibility to choose death? Recognizing the expensive nature of continued treatment or of palliative care, how would people facing death perceive their social responsibility? This could all too easily become a major reorientation of society's perception of its responsibility to the most vulnerable. Do we wish to reshape fundamentally the relationship between the patient, the doctor, and society along these lines? As we have noted previously in our concern over issues of "determination" such a change would have dramatic and seriously problematic consequences for us, both personally and as a society.
As we have noted above, we remain deeply concerned when questions of control and power enter into the forefront of our common debate. Such considerations overpower that sense of mutual responsibility which is so critical to our lives together. Once that sense of responsibility and interdependence erodes, the poor, the isolated, and the vulnerable likely will pay the price. We stand strongly against any such impoverishment of our common discourse.
C. Compassion not pity
In response to our call to mutual responsibility, one can, of course, raise the critical question of how to protect the dignity of the person who is suffering. Given the Church's deep concern for justice, and especially for those who are most disadvantaged, we find that question most appropriate. We recognize fully the compelling need to respond to suffering men and women. If one cannot guarantee in some way the dignity of persons in such difficult circumstances, then the arguments raised here could seem only so much wordplay. As we noted above, however, the response must find its roots in a growing sense of compassion, not pity. We now sketch some of the implications of this perspective.
The meaning of suffering and the value and dignity of the person who suffers become critically important. We would not argue that suffering always ennobles nor that suffering represents a good. Suffering, in all of its dimensionsthe physical, the psychological, the socialchallenges the very core of human life. It reveals our weakness and vulnerability. It can isolate us, especially in a world which shields itself so often from the reality of human suffering and pain.
"<It is true that Christ suffered and that Christians see his suffering as meaningful. It is also true that Christians have a profound desire to unite themselves to the sufferings of Christ so that the world's quality of life may improve. But when these same Christians are gripped by the sufferings of the terminal phase, they turn in on themselves so much that pain fills the whole of life. They are thus cut off from the love they want to live".>
We cannot and do not advocate any argument which portrays pain or suffering as constituting values in themselves, at the same time, we do affirm the value of heroic suffering and as Catholics we affirm the way in which suffering unites us to God and to others in a particular way. While human suffering may lead to life-giving relationships, we have a responsibility, a duty, to make every effort to reduce it. The most vulnerable in our communitiesespecially those who are dyingmust have a priority in the allocation of resources.
In that light, as Catholics we strongly recommend that the current debate pay particular attention to the experience of the palliative care units and hospices which have done such extraordinary work in defending the dignity of men and women facing death.
"<[Palliation is] a form of care that recognizes that cure or long-term control is not possible; is concerned with quality rather than quantity of life; and cloaks troublesome and distressing symptoms with treatment whose primary or sole aim is the highest possible measure of patient care".>
We understand fully that such care cannot eliminate suffering; it cannot even in all cases reduce it. Palliative care certainly is no panacea, though it is an excellent way of affirming the life of the person who is dying.
Indeed, as Catholics we urge our government to consider how it allocates resources. The costs of palliative care would no doubt consume greater sums of money than euthanasia or assisted suicide. As a compassionate nation, however, the quality of our commitment to justice has to be measured by our willingness to place our resources at the service of the dying. Grants toward research in pain control therapies or in methods of patient care would be most appropriate. Especially in the light of the current decrease in the number of palliative care units, we advocate a commitment to making such facilities both more available and more widely known, so that people who are dying may choose the type of care they would like to receive.
Yet suffering arises not only from physical sources; critical, too, is the social dimension of suffering. We strongly encourage a greater involvement of our fellow citizens in the care of the suffering. This would build a deeper sense of mercy or compassion, uniting us in the face of our contemporary fear of death rather than isolating those whose sufferings or death cannot be avoided or controlled. As Catholics we see this as a call from God, a particular way in which we carry out our lives after the pattern of Jesus; we commit ourselves and our community to a real service of the vulnerable. We understand, moreover, the way in which those who suffer can exercise a ministry towards our society, moving our hearts to compassion if we would but listen. All too often, these calls go unheard.
Especially in our era of medical professionalization the greatest burden of the suffering implicit in dying arises as a patient experiences a profound loneliness. Such isolation can seem to envelop the patient, who feels increasingly cut off from his or her social support network. This becomes a particular concern in a society like ours, which is so often marked by individualism, and in which such isolation can be particularly acute. As fellow citizens, as children of one God, we must pay ever deeper attention to the laments which arise from the dying.
These laments can break our hearts; they speak to our frailty and weakness. At the same time, though, we must not allow ourselves to miss deeper connotations of the cries of the dying.
"<The confusion surrounding the issue of euthanasia or assisted suicide derives from a set of false suppositions about palliative care, pain relief, consent and compassion. The central, and most dangerous, of these suppositions is that the dying are crying out for death. There has been widespread failure to appreciate the role and function of lamentation in human experience and clinical practice. Clinicians have the privilege to hear and even to share in their patient's lament of pain, fear and helplessness. At the heart of this lament is not a cry for death but a cry for life. By giving our patients the freedom to cry out their lament without fear of being misinterpreted, we liberate ourselves to return to a more realistic and humble view of vocations">.
We must, in all that we do, affirm that call to life which is expressed in the lament of the one who suffers, and see in that life-affirming response a service of human dignity: that of the one who suffers and our own as people called to mutual responsibility.
It is precisely in this matter that we most strongly reject the arguments for euthanasia or assisted suicide. As they over-emphasize the autonomy and freedom of the patient, they miss the deeper dignity which is fundamentally relational: the call to love and be loved. Dignity lies not in the exercise of the will, nor even in quality of life, but fundamentally in our being relational beings, able to evoke and to give compassion. To lose this ability would be to undermine the very human bonds of our society and to make ever more tenuous the life we share as part of a community. Only in responding to the challenges of an authentic, if often painful, compassion can we give life to that social fabric which so often now seems dangerously tattered. As Catholics, we commit ourselves to this work and invite our fellow citizens to share in it.
Text of Canadian Bishops Conference position paper issued on October 26, 1994.
1 "Euthanasia" in this brief means An action or omission of an action which of itself or by intention causes death in order that all suffering may be eliminated". (Catholic Health Association of Canada, <Health Care Ethics Guide>, 1991.)
2 House of Lords, <Report of the Select Committee on Medical Ethics>, Volume 1-<Report>. London: 31 January 1994, par. 276.
3 Congregation for the Doctrine of the Faith, <Declaration on Euthanasia> (Vatican City, 1980), section I.
4 <Sue Rodriguez and the Attorney General of Canada and the Attorney General of British Columbia>, Supreme Court of Canada, 30 September 1993, Reasons for Decision of the Majority by Mr. Justice Sopinka, page 7.
5 Philip E. Devine, <The Ethics of Homicide> (Notre Dame: University of Notre Dame Press, 1990), 19.
6 Archbishop Marcel Gervais, President of the CCCB, <Statement on Assisted Suicide and Euthanasia>, 13 January 1993. Mr. Justice Sopinka, in the majority judgment in the Rodriguez case, also affirms the important distinctions among refusing or withholding treatment, assisted suicide, euthanasia and palliative care. (See the appendix to this brief.).
7 John F. Scott, M.D., "Lamentation and Euthanasia", <Humane Medicine>, 8, n. 2, 117.
8 Sue Rodriguez case, pages 22 and 23.
9 Law Reform Commission of Canada, Report No. 28, <Some Aspects of Medical Treatment and Criminal Law> (1986) at p. 13.
10 David Cundiff, M.D., <Euthanasia Is Not the Answer: A Hospice Physician's View> (Totowa, NJ: Humana Press, 1992), 63-64.
11 Johannes J. M. van Delden, Loes Pijnenborg, and Paul J. van der Mass, "The Remmelink Study: Two Years Later", <Hastings Center Report>: 23, n. 6 (1993), 26.
12 Writing for the majority in the Rodriguez case, Mr. Justice Sopinka said: "Critics of the Dutch approach point to evidence suggesting that involuntary active euthanasia (which is not permitted by the guidelines) is being practiced to an increasing degree. This worrisome trend supports the view that a relaxation of the absolute prohibition takes us down the slippery slope".
13 Hubert Doucet, <Death in a Technological Society: An Ethical Reflection on Dying> (Ottawa: Novalis, 1992), 146.
14 The World Health Organization, <Palliative cancer care>, as cited in the House of Lords report, at 32.
15 John F. Scott, M.D., "Lamentation and Euthanasia", <Humane Medicine> 8, no. 2, 116.