s of hopeless and painful illness" to bring about "a quick and painless death." The word "painless" is important: the idea of euthanasia began gaining ground in modern times not because of new technologies for agonizingly prolonging life but because of the discovery of new drugs, such as morphine and various anesthetics for the relief of pain, that could also painlessly induce death. Over the next three decades Williams's proposal was reprinted in popular magazines and books, discussed in the pages of prominent literary and political journals, and debated at the meetings of American medical societies and nonmedical professional associations. The debate culminated in 1906, after the Ohio legislature took up "An Act Concerning Administration of Drugs etc. to Mortally Injured and Diseased Persons", which was a bill to legalize euthanasia. After being debated for months, the Ohio legislature overwhelmingly rejected the bill, effectively ending that chapter of the euthanasia debate. 2Euthanasia reemerged in the 1970's, when in 1976 California was the first state to legalize a patient's right to refuse life-prolonged treatment. The Legislature passed the Natural Death Act, which allows for living wills, an advance directive to a doctor requesting the withholding or withdrawing of life sustaining treatment.3 Today, all states have some form of living will legislation. In addition, the individual who wishes to have such a will, may also designate a family member or friend as a proxy to make the decisions for him or her, should he or she be unable to make the decisions himself or herself. Some states also require the individual to sign a power of attorney to do so.4In 1976, the New Jersey Supreme Court decided the parents of Karen Ann Quinlan won the right to remove her from a ventilator because she was in a persistent vegetative state. The justices unanimously ruled that this act was necessary to respect Quinlan's right to privacy.5 Some medica...