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M. Cathleen Kaveny, JD, PhD, John P. Murphy Foundation Professor of Law, in her 1997 Theological Studies article, "Assisted Suicide, Euthanasia, and the Law," explained:
"The term 'euthanasia' in general refers to a situation in which one party adopts a course of action with the intention of causing the death of a second party in order to alleviate suffering...'nonvoluntary' euthanasia is performed on patients who have expressed and can express no view on the matter."
Jonathan Moreno, PhD and Emily Davie and Joseph S. Kornfeld Professor of Biomedical Ethics, in the introduction to his 1995 book Arguing Euthanasia, explained:
"Passive euthanasia in the absence of knowledge of the patient's wishes (nonvoluntary) remains controversial... Within the meaning of active euthanasia, the difference between voluntary euthanasia and nonvoluntary euthanasia is also important... active nonvoluntary euthanasia may be performed on a patient who is not competent and who has not requested it."