Bertha Alvarez Manninen, PhD, Assistant Professor at Arizona State University, in the Nov. 2006 article, "A Case for Justified Non-Voluntary Active Euthanasia: Exploring the Ethics of the Groningen Protocol," published in the Journal of Medical Ethics, argued:

“These infants are terminally ill; modern medicine can do nothing to save them… Continued existence is of no benefit to them; rather, death is often looked upon as a much prayed for blessing. In these tragic cases, death is what constitutes the best interests of the infant and it is on the basis of this realisation that we recognise that passive euthanasia is what the primary moral principle of medicine – to do no harm – calls for.

Needlessly prolonging the lives of these infants counts against their interests, and so we concede to their deaths and allow them to occur…In these cases, the duty to do no harm may entail the positive duty of hastening death.”

Nov. 2006