Terminal Sedation

    "Terminal sedation" is a phrase that is relatively new. It did not even appear in medical literature until the 1990s. Even today, there is not a clear definition of the term.(87)

    It has long been recognized that, in the very rare case when symptoms cannot be relieved in any other way, sedation can be administered even if it renders a patient unconscious. The use of such sedation is not limited to dying patients, but is sometimes used temporarily in trauma or burn cases. And it has been traditionally understood that, even if such an intervention carries the risk of death, it is appropriate and ethical under the principle of double effect. (It should be noted that, contrary to widespread belief, medication – morphine, for example – gradually increased to even extremely high doses to control pain, does not hasten death.(88) And sedation to the point of unconsciousness may even slightly prolong the life of a dying patient.)(89)

    Medical professionals have found the principle of double effect immensely useful as a guide for ethical decision-making.

Principle of Double Effect

The principle of double effect is based in Catholic tradition,(90) but it has long figured prominently as a guide to ethical decision-making in secular settings.(91) According to the principle of double effect, it is morally permissible to perform an act that has both a good effect and a bad effect if all of the following conditions are met:

  1. The act to be done must be good in itself or at least indifferent.
  2. The good effect must not be obtained by means of the bad effect.
  3. The bad effect must not be intended for itself, but only permitted.
  4. There must be a proportionately grave reason for permitting the bad effect.(92)

    It is the third requirement – the intent aspect – that assisted suicide proponents have seized on as the Achilles heel in the principle, claiming that a physician who intended to kill a patient could escape scrutiny by claming the death was unintended.

Distorting the Principle of Double Effect
   In its later-overturned Compassion in Dying ruling, the Ninth Circuit sided with this viewpoint, saying that the "euphemistic use of ‘possible’ and ‘may’ [as in may cause death] may salve the conscience of the AMA, but it does not change the realities of the practice of medicine…."(93) The Court claimed that "in the case of ‘double effect’ we excuse the act," not by sugarcoating the act itself but by hiding the intent behind the facade of the double effect.(94) As an example, the Court referred to providing a morphine drip for a patient and erroneously stated that such an intervention "will indubitably hasten his death."(95)

    Dr. Thomas Preston agreed with the Court’s statements,(96) but his stance was not surprising. Two years earlier, while the case was wending its way to the Ninth Circuit, Preston had written an opinion piece for the New York Times that became the first widely circulated attack on double effect as it pertains to palliative care. In it, he referred to use of double effect as "medical jargon" and said "the morphine drip is undeniably euthanasia, hidden by the cosmetics of professional tradition and language."(97) Preston called on society to come to grips with the fact that euthanasia is widespread now and, therefore, efforts should turn to establishing appropriate guidelines for its practice.

    However, Preston who is a Seattle cardiologist and professor of medicine at the University of Washington was not an objective commentator on the state of medical ethics. He was, in fact, one of four physician-plaintiffs in the Washington case seeking to overturn assisted-suicide laws, as well as a board member and a medical advisor for CID. He was involved in assisted suicides being facilitated by CID.(98)

    The claims made in Preston’s article made their way into the U.S. Supreme Court briefs and arguments. Terminal sedation was said to be the same as assisted suicide, only a more "gruesome"(99) method of doing so than a quick lethal dose of drugs. Tribe called sedation a means to "chemically kill someone."(100) However the Court rejected attempts to equate an intended death with the risk of an unintended death that may accompany sedation.(101)

    Nonetheless, assisted suicide leaders continue to blur the lines between killing patients and killing pain. They persist in declaring that sedation is "slow euthanasia."(102)

    By distorting both the practice of sedating patients and the principle of double effect, assisted suicide advocates are attempting to persuade the public that it is unreasonable to continue to prohibit such deaths. As Dion Aroner said in a public presentation to gather support for her "Death with Dignity" bill, "I don’t see the difference between terminal sedation and physician assisted dying except that the patient has control of one and not the other."(103)

    It is likely that assisted suicide proponents will use this obfuscation as they continue in their attempts to gain public support.

Appealing to the Public
   Among the most effective ways to influence public opinion are declarations issued in conjunction with major events and guest columns in newspapers where the terminal-sedation-as-a-cruel-hypocritical-practice theme has recently been found.

    At an international right-to-die conference held in Boston last year, health-care professionals issued the following declaration:

We are health-care professionals attending the biennial Conference of the World Federation of Right to Die Societies being held in Boston from 1-3 September 2000. We support the right of competent adults who are suffering severe and enduring distress from terminal illnesses to seek medical assistance to hasten dying if this is their voluntary, rational and persistent request, after other relevant options offered by palliative medicine have been fully explored.

On this occasion, we wish to draw public attention to the practice of "terminal sedation" or "slow euthanasia" which is performed extensively today throughout the world in hospitals, nursing homes, hospices and in private homes. This is carried out under the doctrine known as "double effect" by which a physician may lawfully administer increasing dosages of regular analgesic and sedative drugs that can hasten someone’s death as long as the declared intention is to ease pain and suffering. Of course, the key word is "intention." Compassionate physicians without publicly declaring the true intention of their actions, often speed up the dying process in this way.

Many thousands of terminally ill patients are so helped globally every year. We feel that the only real difference between "terminal sedation" and a rapidly effective lethal dose is one of time – a slow death, over a few days, with life-shortening palliative drugs, versus a more dignified and peaceful death, because it is not prolonged, and is determined by the patient. We urge other medical professionals worldwide to be more open about this form of physician-assisted dying.(104)

    Herb Berkowitz, president of Compassion in Dying of Alaska, expressed similar sentiments in a guest column for the Anchorage Daily News when he wrote:

[T]here is a medical solution known as "terminal sedation." This involves putting the patient into a drug-induced coma that is maintained until the patient withers away and dies. This can take weeks. Religious spokesmen consider this a ‘natural’ death, and therefore do not oppose it.(105)

    Within the span of a few years, a rarely used treatment to alleviate uncontrollable pain has come to be depicted as an optional method of intentionally causing death. If such erroneous impressions are not refuted effectively, the confusion that will exist in the mind of legislators, judges and the general public could be devastating.

    Along with their representation of terminal sedation as "slow euthanasia," right-to-die leaders are depending on what they call the "Oregon experience" to further their cause.

The Oregon Experience

    Oregon’s experience with assisted suicide is, by far, the foundation on which activists hope to build support for their agenda. It has already figured prominently in initiative campaigns and in cases before the courts. Speaking to international right-to-die conference attendees, Tucker called official Oregon data "enormously useful." She said, "[W]hat that data shows quite convincingly is that speculative fears that the state has conjured in these cases have not come to pass."(106)

    As discussed earlier, supporters of Maine’s Death with Dignity Act were unsuccessful, in large part, because their claims about Oregon’s assisted suicide law were countered with accurate, documented information about what is happening in Oregon. But that did not deter Tucker from using official Oregon statistics to bolster her arguments before the Alaskan Supreme Court. Tucker assured the Court that official statistics prove that permitting assisted suicide in Alaska would not result in abuses, but would, instead, present an opportunity for people to make careful, reasoned choices about how their lives will end.(107)

    With the failure to advance their agenda in Alaska, assisted suicide activists will focus on Oregon. They will use Oregon as the "poster state" to make claims that assisted suicide is a personal choice that, when legal, is make infrequently and under carefully controlled guidelines. Therefore, it is extremely important to examine the Oregon law itself and the official reports about its implementation.

Oregon’s Law
   Its advocates give solemn assurances that Oregon’s Death with Dignity law is tightly written; is limited to specifically qualified, terminally ill patients; has stringent safeguards; and is carefully monitored to prevent any possibility of abuse. But, under close scrutiny, the actual content of the law raises a number of concerns:

  • Oregon’s assisted suicide law does not require that family members be notified when a doctor is going to help a loved one commit suicide. Family notification is not required, only recommended.(108) The patient’s family doesn’t need to be notified until after the patient is dead.
  • Oregon’s assisted suicide law permits doctors to help mentally ill or depressed patients commit suicide. A referral for counseling is only necessary if, in the "opinion" of the attending physician, the patient requesting death has a "psychiatric or psychological disorder, including depression, causing impaired judgment."(109)

Even then, the law does not preclude people who are depressed or who have psychiatric or psychological disorders from obtaining a prescription for lethal drugs as long as a mental health professional determines that the person’s judgment is not impaired.

Neither early dementia nor other cognitive problems automatically prevent a patient from being "qualified" for assisted suicide.(110) Practice guidelines on implementation of the Oregon law indicate that a person for whom the court has appointed a guardian or conservator can still qualify for assisted suicide. The guidelines merely suggest that doctors notify (not obtain permission from) the guardian or conservator regarding the request for lethal drugs.(111)

Kate Cheney, 85, reportedly had been suffering from early dementia. After she was diagnosed with cancer, her own physician declined to provide a lethal prescription for her. Counseling was sought to determine if she was capable of making health care decisions.

A psychiatrist found that Mrs. Cheney was not eligible for assisted suicide since she was not explicitly pushing for it, her daughter seemed to be coaching her to do so, and she couldn’t remember important names and details of even a recent hospital stay.

Mrs. Cheney was then taken to a psychologist who said she was competent but possibly under the influence of her daughter who was "somewhat coercive." Finally, a managed care ethicist who was overseeing her case determined that she was qualified for assisted suicide, and the lethal drugs were prescribed.(112)

Doctor-shopping played a role, as well, in the case of another elderly woman whose assisted suicide death was showcased by CID. Two doctors -- including her own physician who believed that her request was due to depression -- refused to prescribe lethal drugs for this woman in her mid-80s who had been battling breast cancer for twenty-two years.

But then, CID became involved. Dr. Peter Goodwin, the group’s medical director, determined that the woman was an "appropriate candidate" for death and referred her to a doctor who provided the lethal prescription. In an audio-taped statement, made two days before her death and played at a press conference called by CID, the woman said, "I will be relieved of all the stress I have."(113) [CID later revealed that, of the 15 reported deaths during the statute’s first year, it had "helped" 11 (73.3%) of those who died.(114)]

Furthermore, the waiting period may not withstand a court challenge. The required fifteen day time lapse between the first and second oral requests was included in the Oregon law as a direct result of the failure of the Washington and California initiatives. Speaking at a 1997 conference in Seattle, Tucker explained that the waiting period was inserted into the Oregon proposal to make it palatable to voters, but she opined that the waiting period would be found unconstitutional if it is subjected to a court challenge:

In my view, the Oregon measure, in some sense, became overly restrictive. It has a fifteen-day waiting period. And my own view of the federal constitutional claim is that a fifteen-day waiting period would be struck down immediately as unduly burdensome. But in the legislative forum, to pass, you need to have measures that convince people that it’s suitably protective so you see a fifteen day waiting period."(117)

  • Oregon’s assisted suicide law has no safeguards for the patient at the time the lethal drugs are taken.
    The Oregon law’s safeguards, illusory though they may be, only cover behavior up through the time the doctor writes the prescription for lethal drugs. The law contains no provisions dealing with what happens after the patient receives the prescription. The prescribed drugs could be stored over time, with no concern for public safety or for protecting the vulnerable patient from those who might benefit from the patient’s early demise.

Moreover, even the requirement that the patient’s judgment not be impaired refers only to the time between the patient’s first request for assisted suicide and the doctor’s writing the prescription. Nothing in the law requires that the patient be competent at the time the deadly overdose is taken.

In a 1997 Oregon Bar Association publication about Oregon’s "Death with Dignity" law, CID’s Barbara Coombs Lee and her co-authors wrote, "The Act merely regulates the conduct of all parties up to the point of the drug prescription."(118)

Thus, a doctor who negligently "participates"(120) in an assisted suicide cannot be held accountable so long as he or she claims to have acted in "good faith." On the other hand, a doctor who negligently provides other medical interventions can be held legally accountable in civil court regardless of his or her "good faith."

This lessening of the standard of care for assisted suicide could serve as an inducement for doctors to recommend assisted suicide over palliative care at the end of life.

After passage of Oregon’s law, supporters said the new law would permit the types of activities carried out by Jack Kevorkian. In an appearance on Nightline, Geoffrey Fieger (Kevorkian’s attorney) and Peter Goodwin (CID’s medical director) both agreed that the new law would permit use of a death-inducing device such as that developed by Kevorkian.(121)

Speaking at the Ninth National Hemlock Conference on Physician Aid-in-Dying, Tucker said that assisted suicide under the Oregon law "can take many forms" beyond swallowing pills. "I think that technology can make self-administration possible for a very broad range of patients who would not have the wherewithal to self-administer otherwise," she said. "For example, there are certainly technologies that permit patients to do things by voice activation of a computer that could generate an infusion of medication. That can be self-administration."(122)

    Like the law itself, the official reports deserve attention.

The Oregon Assisted-Suicide Reports
   As previously discussed, passage of the Oregon law provided an extremely important tool for assisted suicide proponents to use in their quest to spread legalized assisted suicide across the country. And they have used the official reports from Oregon to refute concerns that the law would result in deaths of vulnerable people who are depressed, under pressure from others, living in poverty, or lacking adequate health care.

    If assessment of Oregon’s experience with assisted suicide depended solely on official reports, those concerns have, indeed, been found to be without merit. However, reliance on those official reports for an accurate portrayal of assisted suicide in Oregon is imprudent.

Physician Noncompliance
   Although descriptions of the law have consistently stated that the law requires physicians to report involvement in assisted suicide, it actually requires only that prescribing doctors maintain documentation in patients’ medical records.(123) The actual "reporting requirements" are directed only at the Oregon Health Division (OHD) which must make rules to facilitate information collection, review a sample of records and issue an annual statistical report.(124)

    The OHD has the mandate of requiring health care providers to file a copy of dispensing records.(125) However, the law contains no penalties for health care providers who fail to report prescribing lethal doses for the purpose of suicide. Moreover, according to Dr. Katrina Hedberg, co-author of Oregon’s three official reports, the OHD has no regulatory authority or resources to ensure compliance with reporting requirements.(126)

Questionable Data
   The OHD acknowledges that information on which its official reports are based may be incomplete and inaccurate. The only physicians interviewed for either report were those who had acknowledged prescribing lethal drugs. The first report stated that among its limitations was the fact that "the possibility of physician bias must be considered."(127) In addition, the OHD conceded, "[W]e cannot detect or collect data on issues of noncompliance with any accuracy"(128) and "We do not know if covert physician-assisted continued to be practiced in Oregon in 1998."(129)

    This situation did not change for subsequent reports. The second official report noted, "Underreporting cannot be assessed, and noncompliance is difficult to assess because of the possible repercussions for non-compliant physicians reporting data to the division."(130)

    The OHD has even admitted that reporting physicians may have fabricated their versions of the circumstances surrounding the prescriptions written for patients: "For that matter, the entire account could have been a cock-and-bull story. We assume, however that physicians were their usual careful and accurate selves."(131)

    Over the course of the first three years of legal physician-assisted suicide in Oregon, 70 deaths were reported.(132) But there is no way to know how many such deaths actually took place. Nor is it possible to determine the circumstances surrounding those deaths.

Questions and More Questions
   Nonetheless, some information that does appear in the Oregon reports raises as many questions as it answers. For example, one patient was reported to have taken the lethal dose more than eight months after receiving the prescription.(133) Lethal prescriptions under Oregon’s "Death with Dignity Act" are supposed to be limited to patients who have a life expectancy of six months or less. However, the OHD is not authorized to investigate how physicians determine their patients’ diagnoses or life expectancies.(134)

    The actual life expectancy of those who died after taking prescriptions for assisted suicide is unknown.

    Official reports from Oregon also indicate that at least 59% of patients did not receive their lethal drug prescriptions from the first physician they asked.(135) Since the refusing physicians were never interviewed by the OHD for the official reports, there is no way to know why these doctors refused to prescribe or why they determined that the patient was not qualified for an assisted suicide death under the Oregon law.

    Was it because the patient was not terminally ill? Was it because the physician was personally opposed to assisted suicide? Or was it because the doctor knew the patient was subtly being pressured or encouraged by others to opt for an early death? The answers to these questions will never be known.

    The OHD’s figures also indicate that some patients knew their doctors for only two weeks before the lethal dose was prescribed.(136)

    Since at least two weeks must elapse between the first and last requests for the lethal dose, it appears that, in these cases, the physician-patient relationship was established for the specific purpose of obtaining the drugs for assisted suicide.

    There are other omissions in the reports that raise even more questions. For example, the reporting doctors stated that none of the patients expressed financial concerns as a reason for wanting to die from assisted suicide. Yet 14.3% of those who died were on Medicaid,(137) Oregon’s health program for the poor. In this population, financial difficulties are a fact of life. Is it possible that physicians did not probe these patients’ reasons for choosing assisted suicide since the difficulties associated with poverty seemed insurmountable?

    Among others whose deaths were reported, there remains a question about financial concerns that may not have been discussed with the prescribing physician (or may have been discussed, but not reported).

    The Oregon law requires the doctor to inform the patient of the "feasible alternatives, including, but not limited to, comfort care, hospice care and pain control."(138) Since these would likely not be "feasible alternatives" for patients who do not have the financial resources to obtain such care, there is even some question as to whether the physician would have to inform a patient about such services.

    In fact, in the absence of the ability to afford such services, being "informed" about them is useless, if not cruel. Even among Oregonians who are covered by private medical insurance, coverage for hospice services is often woefully inadequate. For example, QualMed Oregon Health Plan (created out of a merger of two HMOs) covers assisted suicide "as a prescription" while the plan’s "value option" has a $1000 limit on hospice care for terminally ill patients.(139)