Physician-Assisted Dying Committee on Feb. 1st, 2016

[The Joint Chair (Mr. Robert Oliphant (Don Valley West, Lib.)), Liberal, Rob Oliphant]

I call this eighth meeting of the Special Joint Parliamentary Committee on Physician-Assisted Dying to order.

I hope members of the committee and others had a good weekend. I've missed you tremendously. It's been two days without you.

[Voices]

Oh, oh!

[The Joint Chair (Mr. Robert Oliphant), Liberal, Rob Oliphant]

I'm glad we've all survived.

In our first panel this morning, we have witnesses from the British Columbia Civil Liberties Association, the Justice Centre for Constitutional Freedoms, and Dying with Dignity Canada. Each of those three organizations will have 10 minutes to present. I'm going to suggest that we do them in that order for now.

The committee will then ask questions of all of you or any of you at any particular time.

I don't know whether both of you, Mr. Paterson and Ms. Pastine, are going to speak. You have 10 minutes between the two of you.

Thank you.

[Grace Pastine, Litigation Director, British Columbia Civil Liberties Association]

Honourable senators and members of Parliament, thank you for the opportunity to come before you today.

The BC Civil Liberties Association is the organization responsible for sponsoring and litigating the landmark Carter case. We fought that case on behalf of all Canadians who need a choice at the end of life.

Year after year, in poll after poll, Canadians have overwhelmingly indicated that they support death with dignity, and they expect to have the constitutional right declared by the Supreme Court of Canada in our case honoured by all levels of government.

You have already heard a great deal of testimony concerning the dividing jurisdictional nature of physician-assisted dying in Canada. The provinces and the territories, as you know, have primary constitutional authority over matters of public and individual health. Nonetheless, Parliament does have the power to legislate with respect to federal matters that touch on health, notably through the use of the federal criminal law power.

However, Parliament's power to legislate in this area is not unrestricted. The court did not propose or mandate the creation of a complex federal regulatory scheme to regulate physician-assisted dying. Such a law could be subject to constitutional challenge on the grounds that Parliament has exceeded its jurisdiction. More importantly, as a matter of principle, we think it is profoundly problematic to regulate the delivery of a medical treatment through the prohibitions and penal sanctions of the Criminal Code.

Physician-assisted dying is one of many available compassionate end-of-life health care options that should be available for critically ill individuals. Physician-assisted dying should be regulated in the same manner as comparable end-of-life medical decision-making, such as palliative sedation.

Every day in hospitals around the country patients make decisions to be taken off a mechanical ventilator or to refuse kidney dialysis, and those life-ending decisions are not regulated by the criminal law. That said, there are certain important matters that fall squarely within Parliament's jurisdiction.

Parliament should amend the criminal law to mirror the scope of the Supreme Court of Canada's constitutional declaration, leaving further regulation to provincial legislative authorities and the medical colleges. The court provided explicit guidance to Parliament as to how to remedy the constitutional violation. The court declared that the law is invalid insofar as it applies to a certain category of individuals—that is, it's invalid as it applies to consenting adults who have a “grievous and irremediable” medical condition that causes enduring intolerable suffering.

The Criminal Code should be amended to spell out the qualifications that would substantively entitle an individual to physician-assisted dying. In our view, there's no need to define terms beyond what is already set out in the Carter decision and understood in the criminal and the common law.

“Grievous” is a term that is already employed in the criminal law, and courts have held it to mean serious and non-trivial. “Irremediable”, as defined by the court, is a condition that cannot be alleviated by any means acceptable to the patient. “Intolerable suffering” is suffering that is intolerable to the individual concerned in the circumstances of his or her condition.

“Grievous and irremediable” should not be defined in terms of specific health conditions. It would be impossible to list the full range of illnesses, diseases, and disabilities that would meet the criteria established by the Supreme Court.

Mental illness should not be excluded as a qualifying condition. Many people who are mentally ill are capable for the purposes of making end-of-life decisions.

“Grievous and irremediable” should not be defined as “terminal illness”. The term is too vague, and it's indeterminate and arbitrary. Furthermore, there is no precise science providing a prognosis of terminal illness in terms of a specific length of time.

The Carter decision applies to a competent adult person. In other cases, the Supreme Court of Canada has cautioned against using arbitrary age limits that bear no relationship to an individual's competence to make a medical decision. We urge Parliament to affirm the principle that physician-assisted dying should rest on competence and not on age.

My colleague Josh Paterson will provide further remarks.

[Josh Paterson, Executive Director, British Columbia Civil Liberties Association]

Thank you.

Ms. Pastine has stated our concern about Parliament seeking to comprehensively regulate assisted dying as a matter of the criminal law, but we nevertheless wish to set out what we see as critical elements of any system to govern physician-assisted dying, whoever is doing the legislating.

The evidence accepted and tested by the courts in our case supports the conclusion that physician-assisted dying can be governed by the established norms of informed consent law, which has shown itself to be perfectly adequate as a framework for life-and-death medical decisions.

We trust physicians to do this all the time. Whether a patient is being coerced or pressed by others into a decision, whether they're ambivalent, whether they're vulnerable, or whether they're thinking clearly can all be reliably assessed on an individual basis using the procedures doctors apply in assessing informed consent and decisional capacity in medical decision-making more generally, according to the evidence before the court. No special vulnerability assessments or system of elaborate checks are needed, because the existing system for informed consent does the work that is needed.

However, this doesn't mean that there is no useful role for Parliament or the legislatures. Carter set out a floor, as you've heard many times, but Parliament is free to go beyond that in legalizing physician-assisted dying. For example, the judgment doesn't require that an individual be competent when the assistance is provided, so long as they clearly consent. We see no reason that a person who is competent cannot make a decision now for themselves later, when they may no longer be competent or no longer able to communicate. The Criminal Code should clarify that advance consent is permissible.

Turning to process, there should be no arbitrary barriers created that distinguish this from other kinds of end-of-life treatment. We advise in the strongest possible terms against instituting a review panel or other similar kind of before-the-fact mechanism, as has been urged upon the committee. This is a complete departure from current end-of-life practices. Such a regime would create an undue and totally unnecessary burden on those seeking to access physician-assisted dying, because the courts determined that physicians are entirely capable of dealing with these patient requests under normal medical standards.

Physician-assisted dying is fundamentally a private matter between the patient and the physician. This is a matter of the patient's own autonomy and self-determination. No person, no committee, and no judge should be in a position of having to approve and essentially make the decision for the patient. We've had this issue of committees before in respect of abortion, and the Supreme Court struck down those committees because they posed a barrier to access and because they took away from women their autonomy and choice over their own bodies.

Further, it's a total departure from the normal standards of consent around end-of-life decision-making to require a second opinion from another physician or a specialist. It should simply be an option, as per normal medical standards. The requirement for a second doctor could be particularly onerous in rural and northern communities.

There does not need to be an arbitrary waiting period and a reiterated request. Physicians should be able to use their own judgment, as they do in all cases in which a patient exercises informed consent in respect of an end-of-life decision. Any arbitrary waiting period runs the risk of a patient becoming incompetent in the meantime and being unable to give a second consent, or dying painfully in just the manner that they have the constitutional right under Carter to avoid. This is unjust.

Where a doctor is uncertain that a patient has capacity, there could of course be specialized capacity assessments consistent with the practice for other treatments, but neither a specialized assessment, nor a psychiatric evaluation, nor a vulnerability assessment should be a requirement for all physician-assisted dying requests, as this would be an unduly onerous barrier to access without any justification in the evidence.

As for who can provide assisted dying, as we've heard, the trial decision in Carter referred to a physician or other health care provider acting under the direction of a physician. We support the recommendation of the provincial-territorial panel that Parliament amend the Criminal Code to allow the provision of medical aid in dying by a regulated health care professional operating under the direction of a physician or a nurse practitioner.

Finally, I'd like to say a word about conscientious objection. The BCCLA stands for freedom of conscience and has fought for it regularly in the courts. As we know, physicians are not required to provide physician-assisted death. The solution we would propose is that physicians should have to notify some third party body, whether it's the hospital or the health authority, of their refusal—not provide an effective referral, but simply notify, with the permission of a patient, that they do not want to carry out this service. In that way, there can be a transfer of care for the patient.

In closing I would echo Professor Pelletier in his remarks that Parliament, the legislature, and the colleges may act, but they must not impose a solution that will strip this constitutional right of its meaning for people who desperately seek to die in dignity and peace.

Merci beaucoup.

[The Joint Chair (Mr. Robert Oliphant), Liberal, Rob Oliphant]

Thank you very much, Mr. Paterson.

We'll now go to Mr. Cameron.

[Jay Cameron, Barrister and Solicitor, Justice Centre for Constitutional Freedoms]

Honourable members and honourable Senators, thank you very much for the invitation to be here today.

I'll preface my comments this morning with two thoughts. The first is that I'm aware of the difficult decisions that have to be made by patients and families in palliative situations. I lost my mom seven weeks ago. We cared for her at the house, so I'm very aware, and I'm not taking a moral position with respect to physician-assisted dying or suicide.

My second thought is that despite the fact that the Criminal Code provisions against physician-assisted suicide, paragraph 241(b) and section 14 of the Criminal Code, have been struck down, the history of the medical profession remains, and it is deeply entrenched in the minds and the hearts of many physicians across the country. While the Hippocratic oath, for example, is millennia old and remains in use in various variations across North America today, it has been discarded in some jurisdictions. However, the Hippocratic oath remains in use, and it specifically prohibits giving a patient poison or counselling another person to do so. There are strong conscientious and religious objections that are held by many physicians across the country, and erasing two sections of the Criminal Code does not erase the way they feel about it and what they believe about it.

The Justice Centre for Constitutional Freedoms is an organization devoted to upholding the constitutional rights of Canadians, and increasingly these days the constitutional rights of minorities are threatened. That's typically where our case law lies.

We have five recommendations with respect to pending legislation. They are as follows.

We submit that the new federal legislation should provide explicitly that physicians, nurses, pharmacists, and other health care workers, as well as health care organizations and institutions, can refuse to participate in and refuse to refer for physician-assisted suicide.

The Supreme Court of Canada decision in Carter in no way compels doctors or other health care workers to cooperate unwillingly in a physician-assisted suicide scenario. Carter was predicated on two key factual conditions: a willing patient and a willing doctor. None of the scenarios before the court in Carter involved an unwilling doctor. The existence of a right of patients to require every physician to refer for every medical service is a misconception that some of the provincial colleges of physicians, as well as the Canadian Medical Association, appear to be labouring under. Many doctors and other health care workers object to assisted suicide on ethical, moral, or conscience grounds, or on historical grounds with respect to their profession, which does not negate the fact that their objection is one of conscience. The Supreme Court of Canada in R. v. Big M Drug Mart Ltd. made these comments:

Freedom can primarily be characterized by the absence of coercion or constraint. If a person is compelled by the state or the will of another to a course of action or inaction which he would not otherwise have chosen, he is not acting of his own volition and he cannot be said to be truly free.... Coercion includes...indirect forms of control which determine or limit alternative courses of conduct available to others.

Our second recommendation is that Parliament should enact legislative protections for medical practitioners substantially similar to those contained in the Civil Marriage Act. In the Civil Marriage Act, specific protections were enacted for individuals and organizations that have a religious or a moral belief that marriage is between a man and a woman to the exclusion of all others. No citizen, because of the Civil Marriage Act, can be sanctioned for expressing or propagating or advocating for the belief that marriage is between a man and a woman. The legislation specifically states that it is not against the public interest to hold or advocate these beliefs, and we submit that this is an analogous situation. There is a jurisdictional overlap between the federal government and the provincial governments, and it brings this issue into line with the Civil Marriage Act situation.

Our third recommendation is that the new federal legislation should mandate that the application process for physician-assisted suicide should continue to be made on a permanent basis to a superior court justice. Currently applications are made to a superior court justice on an interim basis; we say that this should be permanently codified.

There are a number of good reasons to do so, in our respectful submission.

First of all, judges are schooled in the law and the Constitution. Disagreements with respect to legislative overlap and overreach can be reconciled best by a judge, who has been trained to deal with constitutional issues. Second, the courts have already said that they trust a justice to handle this weighty decision. Third, justices are capable of giving justice on a timely basis, as emergent applications to courts are regularly made, and they are regularly available in provincial jurisdictions. Fourth, the superior court justices are better equipped to handle the issues that potentially arise in a case of physician-assisted suicide. For example, there are issues of duress. There may be hostilities among family members over which course of treatment to take. Justices are used to dealing with these hostilities. In our respectful submission, it's not fair to put these responsibilities on the shoulders of a physician. Additionally, justices cannot be sued for malpractice, and they do not have malpractice insurance. We suggest that this may be an issue for physicians who make the decision to terminate somebody's life.

Our fourth recommendation is that the federal legislation should mandate a parliamentary review board to review, every three to five years, the physician-assisted suicides that have occurred and to make recommendations for legislative amendments.

I know there have been proposals that a national review body should be established and that it would be better than having a parliamentary review board. In my respectful submission, that is not the best course of action for a number of reasons. First, the enforcement of data collection and reporting would potentially be difficult for a national review board to handle, as there is no authority over the provinces. It would be difficult to bestow a national body with such powers. A parliamentary review board is already capable of doing what a national review board would be capable of doing. In addition, the national board would not be composed of individuals who are responsible to the electorate. This, of course, is not the case with Parliament. In our submission, this adds an additional level of accountability that is a requirement for issues of life and death.

Our fifth and final submission is that Parliament should note that constitutional infringements are already occurring, or are already suggested to occur, in the guidelines that are being released by the colleges of physicians across the provinces. It would be worth noting that the Canadian Medical Association has essentially said there should be a requirement to refer. It does not consider the referral for physician-assisted suicide as assisting in physician-assisted suicide. Additionally, it seeks to qualify the rights of physicians with respect to a delay component or a time component.

In our respectful submission, there needs to be a careful balancing of the rights of physicians versus those of patients, because the non-autonomous nature of a patient who requires the assistance of a physician calls into question the rights of the assistor.

Thank you so much for hearing me today.

[The Joint Chair (Mr. Robert Oliphant), Liberal, Rob Oliphant]

Thank you, Mr. Cameron.

Ms. Morris or Ms. Gokool.

[Shanaaz Gokool, Chief Operating Officer and National Campaigns Director, Dying With Dignity Canada]

Good morning.

Thank you to the parliamentary committee for inviting Dying With Dignity Canada to these hearings this morning.

We are the national advocacy organization uniquely qualified to speak to this issue. We represent the 84% of Canadians who strongly support physician-assisted dying, and our work is informed by our disability advisory council and our physicians advisory council. We are going to speak to you today about principles for eligibility, protection, and access to ensure a fully functional national framework for assisted dying in Canada.

Before we begin, we would like to address the frequent references throughout these hearings regarding the jurisdictional validity of proposed legislation.

We're not constitutional lawyers; we're concerned about Canadians. We urge that there be cooperation among the federal government, the provinces, and the territories, without which, we are deeply worried, we will be left with a provincial patchwork approach that may mean access for the most desperately ill will depend on whether their province has shown leadership in legislation.

Regarding the issue of eligibility, for us Carter sets the floor, not the ceiling. The Supreme Court stated that competent adults with a grievous and irremediable medical condition that causes them enduring and intolerable suffering should be able to access assisted death. The court agrees that only the person, the individual herself or himself, can decide if their suffering is intolerable. As we've heard this morning, “grievous” is already a term used by the criminal courts, in common language, and in common law to represent serious and very severe conditions. Therefore, we don't require any further definition. We urge this committee not to recommend a pre-approved list of conditions for assisted dying.

I'll now turn it over to Wanda Morris.

[Wanda Morris, Chief Executive Officer, Dying With Dignity Canada]

There is no issue before this committee that is more important than that of advance consent.

In their decision, the Supreme Court justices wrote that to force someone to choose between undergoing a premature, perhaps violent, death and enduring prolonged suffering is a cruel choice. We submit that unless the committee recommends that informed consent be allowed by advance consent, the injustice will continue.

Nowhere does this play out more than around the issue of dementia. In the years that I have been speaking about this subject, it's hard to overestimate the number of people who have expressed their fears, their dread, of living for years with dementia. In my home province of British Columbia, we have seen this play out in two cases, that of Margot Bentley and Gillian Bennett.

Margot Bentley was a dementia nurse. She knew that she never wanted to live in a demented state, and yet she has ended up, despite previous written wishes, in a care facility. Against her family's objections, she continues to be spoon-fed, even though she has stage seven dementia, the final stage. She is unable to communicate, is unaware of her surroundings, and has no control of her bodily functions. Perhaps in response to this, we have the situation of Gillian Bennett, a psychotherapist in British Columbia who wrote in her blog, deadatnoon.com, about her decision to end her life before her dementia left her incapable of doing so.

There is another clear case where individuals must have the right to provide advance consent to assisted dying. That is when assisted death is imminently scheduled, but after clearing all the safeguards and protocols, an individual becomes incompetent. Perhaps it's a patient who agrees with her doctor to have an assisted death on Monday but lapses into a coma on Sunday afternoon.

I now turn to the questions of safeguards and access. I remind the committee that you need to bear in mind that we must support two vulnerable populations here. There are those individuals who are socially vulnerable and may be at risk of being coerced into a death that they would not choose, and there are also those who are sick and dying, who are suffering grievously and want to ensure that they have access to this court-promised right. While doctors deal with life-and-death medical decisions every day, we accept that Canadians want to see additional safeguards in the area of assisted dying, and we believe there are two that are important. The first is that a second doctor be involved in this unique case to ensure that a patient is giving voluntary, free, and informed consent. The second is that at least initially, we believe that every single case of assisted dying should be reviewed after the fact and that there should be an aggregate review to identify any systemic issues.

We categorically reject the idea that there should be some kind of panel reviewing requests for assisted death in advance. This is not a safeguard, but a barrier. It is an obstruction to access. It would take assisted dying out of the medical realm, where it belongs, and put it in the justice system. Furthermore, in no regime where assisted dying is legalized—in Quebec, in North America, or in Europe—is this provided for. There is no regulatory support for this from the colleges, and there is no credible evidence of public support for this measure.

We do accept the premise that there are individuals who are vulnerable and that there should be protections, but why would we restrict that just to people who are seeking an assisted death? Why would we not want to also ensure that someone who is asking to be removed from life support or to stop chemotherapy or dialysis would also have a vulnerability assessment? We believe the responsibility for that should fall squarely on the shoulders of the physicians, the ones who are making decisions about capacity every day. If, as others have said, physicians are not trained to do this, we can think of no group better able to learn and to carry out this critical task.

I now want to turn to the issue of access.

My colleague has talked about the need of the Supreme Court to reconcile the rights of doctors and patients. Although the Supreme Court didn't compel doctors to provide an assisted death, that is not something we argue for. We believe every physician should have the right to refuse to either prescribe or administer medication, but we think it's critical that patients' rights be acknowledged too. Simply allowing doctors to turn their backs on patients and walk away does not serve patients or the health care system well.

Patients must not just be left with the Yellow Pages and information to find their own doctor. They need support and access, and we think there's a very expeditious way for the committee to recommend that this happen. It's through transfer of care. Quebec's legislation talks about a doctor notifying their institution. That would be an acceptable solution to us.

What we do not believe is that patients should be left to fend for themselves. In the event that there is not a system in place to expedite care, then the responsibility must fall on doctors to provide effective solutions and effective referral. Ultimately, the health care system must be here to support patients, not to answer to the wishes of doctors.

Finally, I'd like to talk about the roles of institutions. In the final bill in Quebec, there were some concessions made whereby stand-alone hospice palliative care facilities were allowed to choose not to provide an assisted death. We have also heard from many religiously affiliated institutions that they do not believe that assisted death should be provided on their premises.

We do not accept that bricks and mortar have a right of conscience. If a taxpayer-funded institution has patients who are eligible for assisted dying, they must provide it. It is not up to them to deny patients their charter right, nor can they discipline doctors who are acting on their conscience to provide a qualified patient within the framework of the law with the right to the assisted death they seek.

We remind the committee that your decisions and recommendations will affect how Canadians die for decades to come. We urge you to consider two core Canadian values: that of compassion, and that of patient autonomy, or what we call choice.

Thank you.

[The Joint Chair (Mr. Robert Oliphant), Liberal, Rob Oliphant]

Thank you to our five witnesses for your presentations this morning. My co-chair is always pleased when you're right on time, and we're both always pleased when it's so thoughtful. Thank you.

For questioning, we first turn to Ms. Dabrusin.

[Julie Dabrusin, Liberal, Toronto—Danforth, ON]

My first question is for Mr. Paterson.

Could you please comment on Mr. Cameron's suggestion that it would be best to continue to refer cases to courts to decide whether a person should be allowed to have physician-assisted dying?

[Josh Paterson]

Thank you for your question.

We are completely opposed to the proposition that there be a requirement for any sort of prior approval that goes beyond a patient and their physician coming to a decision on treatment, and of course it's the patient who will be making the decision and the physician who is going to provide the treatment.

We think it's a violation of people's privacy rights. It's completely different from anything we do in other kinds of end-of-life care. It's not the standard that's been used almost everywhere around the world but for one country, and there our evidence is a little scanty, as you will remember from a few meetings ago.

We do not endorse that. In fact, we quite oppose it. Also, we think that has a great potential to put in place barriers that for some people may be insurmountable, not only in rural and northern areas but also in cities. As I said earlier, we've seen these kinds of barriers before in relation to medical decisions that really should be autonomous decisions for a patient.

[Julie Dabrusin, Liberal, Toronto—Danforth, ON]

Thank you.

You suggested a system when we were talking about conscience rights. You were suggesting a system whereby a physician would be able to tell a third party that they had objected.

[Josh Paterson]

Yes.

[Julie Dabrusin, Liberal, Toronto—Danforth, ON]

It would be simply that they had objected. Could you flesh that out a little more as to how that system would look? Who would be this third party? What would that look like?

[Josh Paterson]

This, we think, is actually a matter for the provinces, because it's about regulating access. Quebec provides an excellent example. Essentially we endorse the model that Quebec uses. In Quebec it's a local health authority. It would be up to provinces to figure out the appropriate body to notify. Perhaps it would be the hospital, or another body could be designated. In British Columbia we have regional health authorities.

The key is that the body would then be under an obligation to contact, as quickly as possible, the patient who has given consent for that information to be transmitted to them. That body would then be in charge of setting the patient up with someone who can provide the service. It gets the doctor out of having to make an act of referral. They simply have to tell someone that they're refusing.

We don't think that's too much to ask. The interest in conscientious objection is a carefully qualified interest. It isn't absolute. We think that forcing a physician to engage in an act of referral would be going too far, but this is an accommodation that would serve everyone.

[Julie Dabrusin, Liberal, Toronto—Danforth, ON]

Okay. Thank you.

You mentioned there is a privacy issue about the patient having to give consent for that information to go to the third party. Do you foresee any stumbling blocks in that connection? Is there anything we should be watching for in that part of the procedure in order to ensure that there's proper information available for the patient?

[Josh Paterson]

We think it would be a matter of simply asking the patient. Presumably the patient is in a conversation with the doctor who is refusing, a doctor who, under the norms of informed consent, would have had to provide information about the treatment. We would not excuse doctors from that obligation.

It would simply be a matter of saying to the patient, “May I indicate my refusal to this body?” If they say yes, then the doctor can do that. If they say no, then the doctor doesn't have the permission to make that indication.

[Julie Dabrusin, Liberal, Toronto—Danforth, ON]

All right.

[The Joint Chair (Mr. Robert Oliphant), Liberal, Rob Oliphant]

You have 30 seconds.

[Julie Dabrusin, Liberal, Toronto—Danforth, ON]

Okay. I'll be quick.

Ms. Morris, when I looked at the legislative framework that your organization put forward, I saw a system for mandatory referrals. You restricted it to physicians and pharmacists in that framework. Why is that?

[Wanda Morris]

We believe that ultimately a patient should have an effective referral, but if that can be accomplished by a transfer of care, we're happy to work with others to achieve a reasonable result.

I'm not sure where it says that it's just physicians and pharmacists. We saw the two potential stoppages as a physician who wouldn't refer or a pharmacist who wouldn't fill a prescription, but certainly we think no health care professionals should be able to obstruct the process.

[The Joint Chair (Mr. Robert Oliphant), Liberal, Rob Oliphant]

I think I have to cut you off here. We may ask for a written response if we need a further answer. Thank you very much.

Mr. Cooper.

[Michael Cooper, Conservative, St. Albert—Edmonton, AB]

Thank you.

My question relates to mature minors. It's directed to the BC Civil Liberties Association as well as to Mr. Cameron.

If the Supreme Court contemplated mature minors—persons under the age of 18—having euthanasia or assisted suicide available to them, why would the court not simply have said so? Instead, the court repeatedly—at paragraph 68, paragraph 127, paragraph 147—referred to a competent “adult person” as opposed to a competent “person”. Indeed, when you look at paragraph 111 of the decision, the court went so far as to say that euthanasia for minors “would not fall within the parameters suggested” by the court.

I'd be interested in your comments.