I completely agree with Professor MacIntosh's comments. Carter is based upon the idea that it is unconstitutional to deny people who are suffering intolerably the right to have a suitable end to their life that's done in a compassionate way. There's nothing in Carter that would say you only have that right if you're over the age of 18 and you don't have that right if you're under the age of 18.
Again, I don't think that it is completely essential for this analysis to look at the difference between an active ending of life and a denial of treatment, which has the effect of ending life. However, to the extent that it is relevant, the trial court in Carter completely rejected that as a false dichotomy, and said that the dichotomy does not exist, essentially. It's the same issue. People are being given the right to make decisions that will result in the termination of their life.
Thank you.