Ezekiel J. Emanuel, MD, PhD, Chair of the Department of Clinical Bioethics at the National Institutes of Health, in his 2000 article "A Time to Die: The Place for Physician Assistance," that appeared in the Journal of Health Politics, Policy and Law argued:

“Frequently, people indicate that their support for… PAS [physician-assisted suicide] is based on the fact that they would not want to live ‘hooked up to machine’ or ‘when it’s hopeless:’ Advocates of euthanasia and PAS encourage such thinking when they elide the moral and legal distinctions between intentionally ending a life through an intervention, such as an injection of muscle relaxants, and stopping medical treatments [passive euthanasia]…

In June 1997 the U.S. Supreme Court made quite clear that these actions are legally distinct. There is a constitutional right to refuse medical treatments and even have a proxy exercise that refusal, while, by a vote of 9 to 0, the Court clearly stated that there is no constitutional right for either euthanasia or PAS. There is also a moral distinction. The safeguards we think appropriate and necessary for permitting euthanasia or PAS are not necessary for terminating medical care… Such differences in safeguards bespeak different moral evaluations about stopping medical interventions and actively injecting a patient with a life-ending drug.”