Canada Swallows the Hemlock

Over the past four decades, the Western World has been debating legalizing euthanasia. Despite the efforts of its proponents, over many years, almost all efforts at legalization failed politically and in the courts. In the most notable of these failures, in 1997, the Supreme Court of the United States refused to enact an assisted suicide Roe v. Wade, ruling unanimously that the U.S. Constitution does not include a right to assisted suicide. [i]

But euthanasia proponents are zealous in support of their cause. Lose one year, and the very next, they will come back again, and then again, and again. Over time, this unremitting advocacy barrage—supported by the media and popular entertainment outlets—has, like ocean waves eroding a shoreline, eaten away at societal resistance to the suicide agenda. Oregon became the first jurisdiction to formally legalize assisted suicide for those diagnosed with a terminal illness in 1994, narrowly passing a voter initiative known as Measure 16. [ii] (The law went into effect in 1997.)

The Netherlands—which had permitted a decriminalized approach since the 1970s, formally legalized voluntary euthanasia in 2002, as did Belgium. In both nations, euthanasia is available to people with disabilities, certain elderly people, including those with dementia, and the chronically and mentally ill. [iii] Luxemburg also allows it, while Switzerland has long permitted assisted suicide, leading to the contemporary phenomenon known as “suicide tourism.” Colombia’s Supreme Court created a right to euthanasia years ago, but the policy still hasn’t been implemented. Meanwhile, in the years following the passage of Measure 16, three additional U.S. states—Washington, Vermont, and California—enacted statutes allowing assisted suicide for the terminally ill. (In addition, a muddled Montana Supreme Court ruling declared that while there is no state constitutional right to assisted suicide, the act is not against the state’s public policy. [iv] The exact meaning of that ruling is contested among legal analysts.)

During these decades, Canada has also been embroiled in the euthanasia/assisted suicide debate. Indeed, back in 1993, the Supreme Court of Canada ruled 5-4 against the claim of a terminally ill amyotrophic lateral sclerosis patient named Sue Rodriguez that the Canadian Charter guaranteed a right to assisted suicide. [v] And for years thereafter, attempts at legalization in Canada met the same kind of failures that have occurred repeatedly in the United States and throughout most of the western world.

Euthanasia Comes to Canada

Then, with astonishing rapidity, Canada’s resistance to the culture of death collapsed. In less than two years, Canada went from a nation in which assisted suicide was a federal crime to a nation enacting one of the most radical euthanasia legalization regimes in the world.

Quebec: The Canadian embrace of euthanasia was launched in Quebec, probably Canada’s most politically liberal province. In 2014, its parliament enacted “Bill 52,” which created a legal right to “receive end of life care”—a term redefined from the usual medical meaning of hospice and palliative services to explicitly include the administration of a lethal injection, defined under the euphemistic term, “medical aid in dying:”

For the purposes of this act…“medical aid in dying” means care consisting in the administration by a physician of medications or substances to an end-of-life patient, at the patient’s request, in order to relieve their suffering by hastening death. [vi]

To qualify for euthanasia Quebec law requires:

Only a patient who meets all of the following criteria may obtain medical aid in dying: (1) be an insured person within the meaning of the Health Insurance Act (chapter A-29); (2) be of full age and capable of giving consent to care; (3) be at the end of life; (4) suffer from a serious and incurable illness; (5) be in an advanced state of irreversible decline in capability; and (6) experience constant and unbearable physical or psychological suffering which cannot be relieved in a manner the patient deems tolerable. [vii]

Ironically, assisted suicide was not included in the definition. There was a method to this seeming anomaly. Federal law controlled the crime of assisted suicide. But like US states, the provinces each regulate the practice of medicine within their borders. By requiring the direct action by a doctor to end life, the province sought to redefine mercy killing into just another medical procedure, thereby allowing the provincial definition to control rather than that found in the federal criminal statute.

Quebec’s statute was merely the opening stanza of a dark symphony. Soon thereafter, the Canada Supreme Court ended the debate about whether euthanasia should be legal, and shifted it to the question of which conditions and symptoms would permit a doctor to intentionally end a patient’s life via lethal intervention.

The Supreme Court Conjures a Charter Right to Euthanasia:  On February 6, 2015, the Canadian Supreme Court trampled democratic deliberation over the issue by unanimously conjuring a broad constitutional right to “termination of life” for anyone who has an “irremediable medical condition” and wants to die. [viii] Not only did the Court ruling merely legalize euthanasia, but ruled that for those with a “grievous illness or disability,” it is protected Charter right. From the decision:

Insofar as they prohibit physician-assisted dying for competent adults who seek such assistance as a result of a grievous and irremediable medical condition that causes enduring and intolerable suffering, ss. 241 (b) and 14 of the Criminal Code deprive these adults of their right to life, liberty and security of the person under s. 7 of the Charter.

The right to life is engaged where the law or state action imposes death or an increased risk of death on a person, either directly or indirectly. Here, the prohibition deprives some individuals of life, as it has the effect of forcing some individuals to take their own lives prematurely, for fear that they would be incapable of doing so when they reached the point where suffering was intolerable.

The rights to liberty and security of the person, which deal with concerns about autonomy and quality of life, are also engaged. An individual’s response to a grievous and irremediable medical condition is a matter critical to their dignity and autonomy. The prohibition denies people in this situation the right to make decisions concerning their bodily integrity and medical care and thus trenches on their liberty. And by leaving them to endure intolerable suffering, it impinges on their security of the person.

The prohibition on physician-assisted dying infringes the right to life, liberty and security of the person in a manner that is not in accordance with the principles of fundamental justice. [ix]

The scope of the judicial fiat was intentionally not limited to the terminally ill. To the contrary, the Court took a radical leap, allowing euthanasia for virtually anyone with a serious medically diagnosed condition. From the ruling (my emphasis):

[Criminal laws against assisted suicide] unjustifiably infringe s. 7 of the Charter and are of no force or effect to the extent that they prohibit physician-assisted death for a competent adult person who (1) clearly consents to the termination of life and (2) has a grievous and irremediable medical condition (including an illness, disease or disability) that causes enduring suffering that is intolerable to the individual in the circumstances of his or her condition. [x]

The ruling was even broader than those words suggest. For example, a treatable condition can qualify as “irremediable” if the patient chooses not to pursue available medical remedies.

“Irremediable”, it should be added, does not require the patient to undertake treatments that are not acceptable to the individual. [xi]

In other words an “irremediable” condition that permits life-termination may actually be wholly remediable, except that the patient would rather die than receive care.

Imagine the hypothetical Sally, with diabetes (or HIV, heart disease, neuropathy, early-stage cancer, you name it) that can be fully controlled by medication. She decides she wants to die (for whatever reason) and claims that available treatments are “not acceptable” to her. Presto-chango, her theretofore treatable illness is suddenly transformed into an irremediable condition. Ditto (it would seem) Harley, who becomes clinically depressed and chronically suicidal after his business fails—which could readily be considered a diagnosable “grievous illness, disease, or disability”—and refuses psychiatric treatment in order to receive doctor-administered death.

But there’s more: The Supreme Court not only invalidated the federal law prohibiting assisted suicide for those with an irremediable medical condition, but also the law that states, “No person is entitled to consent to have death inflicted upon him, and such consent does not affect the criminal responsibility of any person by whom death may be inflicted on the person by whom consent is given.” [xii] That provision was held to be unconstitutional when applied in the medical circumstances described above. Hence the court created a right in the Canadian Charter of Rights and Freedoms to Dutch-style active lethal injection euthanasia.

Twenty-two years previously, the Supreme Court of Canada had ruled that there was no Charter right to assisted suicide. Now, with the flip of a judicial switch, there is a right to active euthanasia. It is worth nothing that the Canadian Charter of Rights and Freedoms didn’t change during that time. Rather, the arrogance of judges did.

The Political Reaction

Those who (like me) hoped the Canadian people and medical establishment would push back against the decision were flabbergasted at how easily the country swallowed the hemlock. Rather than pushing back against judicial overreach, or suggest that the Parliament temporarily void or hold the ruling in abeyance as permitted under the Charter [xiii] in order for an extended national debate take place, polls showed that most Canadians didn’t oppose such a culture-changing policy being imposed by unelected judges. Soon, the political leadership and medical associations enthusiastically jumped to the tasks of creating the legal and ethical criteria to govern doctor-administered death.

The Supreme Court, in its graciousness (he wrote sarcastically) gave the government one year—later extended by four months—to craft laws consistent with the ruling. There was a pause for a time. But once the Liberals won a majority of the House of Commons, Prime Minister Justin Trudeau’s government leaped to the task of legalizing euthanasia by statute.

Government commissions were empaneled, and medical associations weighed in. The Provincial-Territorial Expert Advisory Group on Physician-Assisted Dying Final Report, as just one example, epitomized the general approach. [xiv] The report is shocking in its enthusiastic embrace of medicalized killing. Brought forward under the auspices of the Ontario Minister of Health and Long-Term Care and the province’s Attorney General, the “experts” issued forty-three recommendations, which if accepted, would transform Canada’s healthcare system into the most radically pro-euthanasia regime in the world.

Here are just a few of the recommendations, followed by a brief description of why they are important:

• “All provinces and territories should ensure access to physician-assisted dying, including both physician-administered and self-administered physician-assisted dying.” [xv] Assisted-suicide advocates often claim that the requirement of self-administration is a crucial safeguard to protect the weak against non-voluntary death. In actuality, coercion can easily happen behind closed doors. Moreover, since studies in the Netherlands have shown that lethal injection has far fewer side effects—such as convulsions and extended coma—than swallowed prescribed overdoses, the application of hastened death will tend to be homicidal.
• “The provision of physician-assisted dying [should also be permitted] by a regulated health care professional (registered nurse or, if applicable, physician assistant) acting under the direction of a physician, or a nurse practitioner.” [xvi] Nurses always get the dirty jobs. Allowing nurses to do the actual killing of patients not only normalizes euthanasia—giving it the appearance of just another routine medical “treatment”—but also isolates doctors from personally participating in killing, making the death prescription that much easier to dispense.
• “We do not recommend a prescribed waiting/reflection period.” [xvii] People legally qualified for euthanasia who want to die now will be able to do so without waiting the time during which some find a renewed desire to live. (Adding to the danger, the committee recommends that euthanasia be available “any time” after receiving a death-qualifying diagnosis. This is particularly reckless, since the initial shock of a serious diagnosis can cause temporary thoughts of suicide.)
• “Access to physician-assisted dying should not be impeded by the imposition of arbitrary age limits . . . eligibility for physician-assisted dying is to be based on competence rather than age.” [xviii] This opens the door to child euthanasia—meaning that boys and girls who cannot legally consent to being tattooed could be able lawfully to order themselves killed.

While it is true that all of these recommendations did not ultimately become part of the Canadian law, they illustrate the true agendas of the international euthanasia movement—and where Canadian euthanasia is likely to go in the coming years.

Bill C-14: On May 30, 2016, Canada’s House of Commons passed legislation that legalized euthanasia and assisted suicide throughout the country—euphemistically described as “medical assistance in dying. The bill was controversial—not because it legalized medicalized killing—but because it appeared to be a bit more restrictive than the wide-open paradigm established by the Supreme Court. [xix]

Specifically, C-14 contains a clause implying that a terminal illness is required a predicate to receiving euthanasia (my emphasis):

(2) A person has a grievous and irremediable medical condition only if they meet all of the following criteria:

• (a) they have a serious and incurable illness, disease or disability;
• (b) they are in an advanced state of irreversible decline in capability;
• (c) that illness, disease or disability or that state of decline causes them enduring physical or psychological suffering that is intolerable to them and that cannot be relieved under conditions that they consider acceptable; and
• (d) their natural death has become reasonably foreseeable, taking into account all of their medical circumstances, without a prognosis necessarily having been made as to the specific length of time that they have remaining. [xx]

In reality, while appearing a bit more restrictive that the criteria dictated by the Supreme Court, C-14’s protections are mostly a mirage. First, the question of suffering remains completely subjective and left solely in the discretion of the patient who wants to die. Moreover, the term “reasonably foreseeabe” would clearly allow patients not actually in a presently terminal condition—of the kind that qualifies a patient for hospice care, for example—to receive euthanasia under the law. Consider a hypothetical cancer patient unlikely to be cured in the long term, but who, with treatment, could be reasonably be expected to live for several years in a somewhat debilitated conditon. A doctor could easily interpret such situations as an advanced state of irreversible decline, and view the patient’s ultimate death is certainly “reasonably foreseeable,” but not yet in a “terminal” stage. The same could be said of other ultimately fatal conditions such as the HIV patient suffering from continuing infections or the diabetic who requires amputations.

Beyond that modest hedge, with the enactment of C-14, Canada adopted one of the world’s most radical euthanasia laws For example, all other countries and U.S. states restrict the application of assisted suicide or euthanasia to physicians. But in Canada, that deadly task could be executed by non-MD certified physician’s assistants:

Medical assistance in dying means

• (a) the administering by a medical practitioner or nurse practitioner of a substance to a person, at their request, that causes their death; or
• (b) the prescribing or providing by a medical practitioner or nurse practitioner of a substance to a person, at their request, so that they may self-administer the substance and in doing so cause their own death. [xxi]

Moreover, it would appear to permit ward and home healthcare nurses to do the actual killing, as well as people completely untrained in medicine, such as family members, friends, even strangers to participate in making the legally qualified patient dead.

Exemption for Person Aiding Practitioner:

No person is a party to culpable homicide if they do anything for the purpose of aiding a medical practitioner or nurse practitioner to provide a person with medical assistance in dying in accordance with section 241.‍2. [xxii]

This means that a doctor can prescribe lethal drugs and anyone can help the patient ingest them. Since such actions would take place behind closed doors, no one would be the wiser if the patient had not actually decided for herself that the time had come to die.

The Senate Balks: Like the United States, Canada has a bicameral legislature. Thus, before euthanasia could be formally legalized by statute, C-14 had to pass the Canadian Senate. But the Senate balked. It wasn’t that C-14 was too loose in allowing euthanasia. It wasn’t that non-doctors would be allowed to kill legally qualified patients. Rather, the majority of the Senate believed that the “foreseeable” death clause was too restrictive and not fully in keeping with the Supreme Court’s ruling and removed the “foreseeable” clause from its version of the legislation. Eventually after passing a version of C-14 without the “reasonably forsseeable” clause, in the end the Senate accepted the bill as enacted by the House of Commons. The law went into effect June 17, 2016. [xxiii]

A Launching Pad, not a Ceiling

The passage into law of C-14 is not likely to be the ceiling of legalized euthanasia in Canada, but rather, more of a launching pad to an even more radical euthanasia regime. Indeed, Prime Minister Troudeau said of C-14, it is a “first step.” [xxiv]

As soon as the law went into effect, political agitation began to expand the killing license to include suffering people whose deaths do not meet the “reasonably foreseeable” standard. [xxv]

Even more to the point, it is likely that the assuming the “foreseeable death” standard will not survive a constitutional challenge. Indeed, even before the law was officially passed, a court ruling from Alberta already ruled that it does not. From the decision:

As Canada fairly conceded, the language of the declaration itself is broad and rights based. Nowhere in the descriptive language is the right to physician assisted death expressly limited only to those who are terminally ill or near the end of life. Canada accepts that a dictionary definition of “grievous and irremediable” medical condition could include conditions that are not life-threatening or terminal. [xxvi]

There is also the question of whether the mentally ill will qualify to be killed. Considering the wording of the Supreme Court’s ruling, assuming decisional capacity, I don’t see how such conditions—which can be excruciating for a far longer time than terminal or serious physical maladies—can be logically excluded. Indeed, Belgium and the Netherlands permit doctors to euthanize the terminally ill. [xxvii] Another issue now under debate in Canada is whether people should be able to instruct that they be euthanized should lose capacity due to dementia or other such conditions, as is now permitted in the Netherlands and Belgium.

Then, there is the question of whether doctors and other medical personnel with religious or conscience objections to euthanasia can refuse to participate when a legally qualified patient askes to be killed. The Supreme Court refused to rule on the question, but strongly implied that qualified patients would have to be guaranteed access to hastened death in some fashion (my emphasis):

In our view, nothing in the declaration of invalidity which we propose to issue would compel physicians to provide assistance in dying. The declaration simply renders the criminal prohibition invalid. What follows is in the hands of the physicians’ colleges, Parliament, and the provincial legislatures.

However, we note — as did Beetz J. in addressing the topic of physician participation in abortion in Morgentaler — that a physician’s decision to participate in assisted dying is a matter of conscience and, in some cases, of religious belief (pp. 95-96). In making this observation, we do not wish to pre-empt the legislative and regulatory response to this judgment. Rather, we underline that the Charter rights of patients and physicians will need to be reconciled. [xxviii]

While it doesn’t appear that doctors will be compelled to participate in euthanasia in the initial federal legislation, the long-term prospects for maintaining such conscience rights are questionable. Many of those supporting euthanasia want all doctors required to participate in euthanasia—either by doing the deed personally or being required to refer to a physician the original doctor knows will be willing administer the lethal drugs. Here’s how the federal advisory panel put it:

RECOMMENDATION 10 That the Government of Canada work with the provinces and territories and their medical regulatory bodies to establish a process that respects a health care practitioner’s freedom of conscience while at the same time respecting the needs of a patient who seeks medical assistance in dying. At a minimum, the objecting practitioner must provide an effective referral for the patient. [xxix]

Gobbledygook: Requiring “effective referral” would materially violate—not respect—a “practitioner’s freedom of conscience” through forced complicity in euthanasia, thereby trampling his faith under the boot of the state.

Meanwhile, provincial medical colleges (associations) were similarly unsympathetic to religious exemptions from participating in euthanasia. Ontario’s College of Physician and Surgeons issued an ethics opinion stating that euthanasia-dissenting physicians have a “duty” to refer legally qualified patients to a doctor willing to kill (redefined as “provide care”)—even if the person asking to die is not a current patient (my emphasis):

Physicians must provide information about all clinical options that may be available or appropriate to meet patients’ clinical needs or concerns. Physicians must not withhold information about the existence of any procedure or treatment because it conflicts with their conscience or religious beliefs. 

Where physicians are unwilling to provide certain elements of care for reasons of conscience or religion, an effective referral to another health-care provider must be provided to the patient. An effective referral means a referral made in good faith, to a non-objecting, available, and accessible physician, other health-care professional, or agency…

The College expects physicians to proactively maintain an effective referral plan for the frequently requested services they are unwilling to provide. [xxx]

In other words, all Ontario physicians are ethically obliged to be complicit in the euthanasia killings of legally qualified patients by—at minimum—procuring the death doctor if religiously or contentiously opposed to euthanasia. Whether doctors who refuse to so participate would face professional discipline remains to be seen.

All of this would seem to fly in the face of Canada’s 1982 Charter of Rights and Freedoms, which states, “Everyone has the fundamental freedom of conscience and religion.” [xxxi] Illustrating the utter lack of regard that secularized Canada now has for religious liberty, the Canadian Civil Liberties Association—that country’s counterpart to the ACLU—applauded the parliamentary committee’s call to stomp upon religious conscience as a “promising step forward.” [xxxii]

Doctors aren’t the only ones threatened with religious persecution under Canada’s looming euthanasia regime. As stated above, provincial and federal commissions have both recommended that nurses, physician’s assistants, and other such licensed medical practitioners be allowed to do the actual euthanizing under the direction of a doctor.

This is particularly worrying from a medical conscience perspective, because it leaves no wiggle room to say no. For example, objecting doctors might be able to defend their refusals by claiming that the euthanasia requester is not legally qualified. Nurses, however, would not even have that slim hope, since they would merely be delegated the dirty task of carrying out the homicide. This leaves nurses with religious objections to euthanasia with the stark choice of administering the lethal dose when directed by a doctor, or being insubordinate and facing job termination. The same conundrum would no doubt apply to religiously dissenting pharmacists when ordered to concoct a deadly brew.

Even Catholic and other religious nursing homes and hospices may soon be required by law to permit euthanasia on their premises, for the federal commission recommended that federal and provincial governments “ensure that all publicly funded health care institutions provide medical assistance in dying.” That is a very broad category. Canada has a single-payer, socialized healthcare financing system that permits little private-pay medical care outside of nursing homes. Not only that, but as Alex Schadenberg, director of the Canada-based Euthanasia Prevention Coalition told me, “religiously-affiliated institutions [in Canada] have become the primary care facilities for elderly persons, those requiring psychiatric care, and dying persons. They are now being told that as a condition of providing those services they will be required to permit doctors to kill these very patients by lethal injection. If they refuse, they will find themselves in a showdown with the government.” [xxxiii]

Can Euthanasia Also Be Judicially Imposed in the USA?

Any question about the desires of American assisted suicide advocates were put to rest when the head of the nation’s most prominent advocacy organization, Compassion and Choices (once known as the Hemlock Society) applauded the ruling in a press release, stating:

We applaud and thank the Canadian Supreme Court for placing the patient at the center of fundamental end-of-life decisions. The eloquence of this ruling will inspire everyone who believes in individual freedom at life’s end. We in the U.S. agree that denying people the ability to determine their own medical treatments and the degree of suffering they endure curtails liberty. [xxxiv]

Realizing they had let the cat out of the bag about its true agenda, the organization later scrubbed the page from its Website, and its director, Barbara Coombs-Lee made all the proper noises about wanting to restrict assisted suicide to the terminally ill.

The real question is what are the prospects of the United States Supreme Court similarly imposing nationwide euthanasia legalization as happened in Canada. In my view, the chances are not high—in the short term. Euthanasia advocates blundered in 1997 by seeking an assisted suicide Roe v. Wade before the issue was ripe culturally, culminating in two 9-0 decisions denying a constitutional right to doctor-facilitated death referenced at the beginning of this essay. Overturning a unanimous decision is far more difficult than one decided by 5-4, as in Canada.

But that should not make us sanguine. I expect assisted suicide advocates to pursue a jurisprudential strategy intended to give the Supreme Court a pretext for eventually revisiting the issue: Obtain rulings by several state supreme courts creating state constitutional rights to “aid in dying”—as of this writing cases are pending in New York and as one is on appeal in New Mexico—while working to legalize assisted suicide through democratic means throughout the country. If sufficient states legalize assisted suicide to the point that a critical mass appears to have formed—say half the states—new cases will be filed arguing that the changed social and legal circumstances justify a second Supreme Court review. Indeed, that is precisely the advocacy approach that succeeded in Canada.

The good news is that there is an effective means of preventing such an apocalypse: Working diligently to keep that kind of critical mass from being reached. If assisted suicide can be bottle up to a few states, it is unlikely the Supreme Court will decide to “end the debate.”

The great Canadian pundit, Andrew Coyne once lamented his countrymen’s widespread support for Robert Latimer, who murdered his 12-year-old daughter Terri because she had cerebral palsy, writing:

A society that believes in nothing can offer no argument even against death. A culture that has lost its faith in life cannot comprehend why it should be endured. [xxxv]

In the end, the question of “what will happen here” depends entirely on whether most Americans-in contrast to our Canadian cousins—retain their faith in the intrinsic importance and ultimate value of each and every human life without regard to illness, disability, age or a perceived quality of life.

[i] Washington v. Glucksburg, 521 USS 702 (1997), Vacco v. Quill, 521 U.S. 793 (1997)

[ii] Oregon Revised Statutes, Chapter 127 https://public.health.oregon.gov/ProviderPartnerResources/EvaluationResearch/DeathwithDignityAct/Pages/ors.aspx

[iii] See Wesley J. Smith, “Euthanasia Spreads in Europe,” National Review, October 26, 2011. http://www.discovery.org/a/17721

[iv] Baxter v. Montana , MT DA 09-0051, 2009 MT 449

[v] Rodrigues v. British Columbia [1993] 3 SCR 519, 107 DLR (4th) 342

[vi] Bill 52, “An Act Respecting End-of-Life Care,” 2014, Title II, Chapter 1, Paragraph 3 (3). (6).http://www2.publicationsduquebec.gouv.qc.ca/dynamicSearch/telecharge.php?type=5&file=2014C2A.PDF

[vii] Ibid. Chapter IV, Division II, Paragraph 26.

[viii] Carter v. Canada (Attorney General) (2015) 1 SCR 331 https://scc-csc.lexum.com/scc-csc/scc-csc/en/item/14637/index.do

[ix] Ibid. (Holding).

[x] Ibid. (Holding).

[xi] Ibid. paragraph 127.

[xii] Ibid, paragraph 20.

[xiii] This is known as the “notwithstanding clasue.” https://en.wikipedia.org/wiki/Section_Thirty-three_of_the_Canadian_Charter_of_Rights_and_Freedoms

[xiv] “Provincial-Territorial Expert Advisory Group on Physician-Assisted Dying Final Report,” November 15, 2015, http://www.health.gov.on.ca/en/news/bulletin/2015/docs/eagreport_20151214_en.pdf

[xv] Ibid. Recommendation 3.

[xvi] Ibid, Recommendation 8.

[xvii] Ibid, Recommendation 26.

[xviii] Ibid, Recommendation 17.

[xix] Bill C-14, http://www.parl.gc.ca/HousePublications/Publication.aspx?Language=E&Mode=1&DocId=8309978

[xx] Ibid., 241.2 (2)

[xxi] Ibid, 241.1.

[xxii] Ibid, 227 (2).

[xxiii] Joan Bryden, “Assisted Dying Bill C-14 Now Law, Canadian Press, June 17, 2016, http://globalnews.ca/news/2769877/senators-bow-to-will-of-elected-commons-on-assisted-dying-bill/

[xxiv] Lianne Laurence, “Trudeau Promises Dissatisfied Liberals that Euthanasia Bill Just a First Step,” LifeSite News, April 20, 2016.

[xxv] For example, see Udo Schuklenk, “Canada’s Assisted Dying Legislation is Unconstitional—Now What?” Globe and Mail, June 20, 2016, http://www.theglobeandmail.com/opinion/canadas-assisted-dying-legislation-is-unconstitutional-now-what/article30520572.

[xxvi] Between the Attorney General of Canada and E.F., 2016 ABCA 155, https://bccla.org/wp-content/uploads/2016/05/Alberta-court-of-appeal-assisted-dying-decision.pdf

[xxvii] See Wesley J. Smith, Culture of Death: The Age of “Do Harm” Medicine, (New York, Encounter Books, 2016).

[xxviii] Carter v Canada, Supra. Paragraph 132.

[xxix] “Report of the Special Joint Committee on Assisted Dying, “Medical Assistance in Dying: A Patient-Centered Approach,” February 2016. http://www.parl.gc.ca/HousePublications/Publication.aspx?DocId=8120006&Language=E&Mode=1&Parl=42&Ses=1

[xxx] The College of Physicians and Surgeons of Ontario, “Professional Obligations and Human Rights, March 2015, http://www.cpso.on.ca/policies-publications/policy/professional-obligations-and-human-rights

[xxxi] Constitution Act of 1982, 2 (a) http://laws.justice.gc.ca/PDF/CONST_E.pdf#page=69

[xxxii] Canadian Civil Liberties Association, “Physician-Assisted Dying Recommendations a Promising Step Forward,” February 29, 2016. https://ccla.org/physician-assisted-dying-recommendations-a-promising-step-forward/

[xxxiii] As quoted in Wesley J. Smith, “Canada Declares War on Christian Doctors and Nurses,” First Things, March 4, 2016, http://www.firstthings.com/web-exclusives/2016/03/canada-declares-war-on-christian-doctors-and-nurses

[xxxiv] As quoted in Wesley J. Smith, “Compassion and Choices Hearts Canada Euthanasia,” Human Exceptionalism, February 6, 2015, http://www.nationalreview.com/human-exceptionalism/398131/compassion-and-choices-hearts-canada-euthanasia-wesley-j-smith

[xxxv] Andrew Coyne, “The Slippery Slope That Leads to Death,” Globe and Mail, November 21, 1994