1. 49. See, e.g., Wheeldon v. Madison, 374 N.W.2d 367, 374 (S.D. 1985); Largey v. Rothman, 540 A.2d 504, 508 (N.J. 1988); Cross v. Trapp, 294 S.E.2d 446, 455 (W. Va. 1982). Cf. Montgomery v. Lanarkshire Health Board, [2015] UKSC 11 ¶ 46 (“The doctor cannot form an objective, “medical” view of these matters, and is therefore not in a position to take the “right” decision as a matter of clinical judgment.”); id. ¶ 115 (“[A] responsible body of medical opinion, becomes quite inapposite. A patient is entitled to take into account her own values, her own assessment of the comparative merits.”). Recognizing the subjectivity of benefit, many encourage clinicians to do as much as possible “for” the patient and as little as possible “to” the patient.
2. 291. Wash. Rev. Code § 7.70.060.
3. 171. See deBrokart, supra note 169.
4. “Voluntarily Stopping Eating and Drinking: A Legal Treatment Option at the End of Life,”;Pope;Widener Law Review,2011
5. 105. The Department indicated that the pamphlet must contain at least five components: (1) a definition and explanation of advanced care planning, hospice care and palliative care; (2) FAQs about hospice, palliative care, and patient rights under the law; (3) a MOLST form and explanation; (4) conversation tools to encourage discussions with the patient's family and providers; (5) a list of licensed hospice providers near the facility; and (6) other requirements defined in the guidance of the Department. M. Biondolillo, “Informational Briefing on Proposed Amendments to 105 CMR 130.000, 105 CMR 140.000 and 105 CMR 150.000: Provision of Information on Palliative Care and Endof-Life Options,” October 16, 2013, available at (last visited February 1, 2017).