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Germany and Switzerland

Netherlands

In April 2002, the Netherlands became the first country to legalise euthanasia and assisted suicide. It imposed a strict set of conditions: the patient must be suffering unbearable pain, their illness must be incurable, and the demand must be made in "full consciousness" by the patient. In 2010, 3,136 people were given a lethal cocktail under medical supervision.

So-called palliative sedation has also become a widespread practice in hospitals, with 15,000 cases a year since 2005, according to the Royal Dutch Medical Association. Patients with a life expectancy of two weeks or less are put in a medically induced coma, and all nutrition and hydration is withdrawn.

The legislation has provoked a fierce debate over the "right to suicide," because assisted suicide outside of the criteria set for euthanasia is still illegal and is counted as homicide.

"Around 10% to 15% of the people who come to us looking for information actually commit suicide", says Ton Vink, head De Einder (Horizon), a foundation that advises people contemplating suicide. To avoid prosecution, he never provides the medicine himself and is not around when somebody takes it. "Most of the people who contact us feel reassured by the information we provide and do not take their life away," he says. Sabine Cessou

France

 

Euthanasia and assisted suicide are against the law. The president, François Hollande, promised to look at the "right to die with dignity" but has has always denied any intention of legalising euthanasia or assisted suicide.

In 2005 the Léonetti law introduced the concept of the right to be "left to die". Under strict conditions it allowed doctors to decide to "limit or stop any treatment that is not useful, is disproportionate or has no other object than to artificially prolong life" and to use pain-killing drugs that might "as a side effect, shorten life".

Two recent high-profile cases have made the headlines: a doctor accused of administering drugs that hastened the deaths of seven elderly patients was acquitted, and France's high court authorised doctors to stop treating and feeding a young man who had been in a vegetative state on life support for six years. In the latter case, the patient's parents have appealed to the European court of human rights and are awaiting a decision. A parliamentary report on the subject is expected at the end of this year. Kim Willsher in Paris

United States

 

Doctors are allowed to prescribe lethal doses of medicine to terminally ill patients in five US states. Euthanasia, however, is illegal. In recent years, the "aid in dying" movement has made incremental gains, but the issue remains controversial.

Oregon was the first US state to legalise assisted suicide. The law took effect in 1997, and allows for terminally ill, mentally competent patients with less than six months to live to request a prescription for life-ending medication. More than a decade later, Washington state approved a measure that was modelled on Oregon's law. And last year, the Vermont legislature passed a similar law. Court decisions rendered the practice legal in Montana and, most recently, in New Mexico.

In 2013, roughly 300 terminally ill Americans were prescribed lethal medications, and around 230 people died as a result of taking them. Some patients choose not to take the medication. Lauren Gambino in New York

Germany and Switzerland

In German-speaking countries, the term "euthanasia" is generally avoided because of its association with the eugenicist policies of the Nazi era. The law therefore tends to distinguish between assisted suicide (beihilfe zum suizid) and "active assisted suicide" (aktive sterbehilfe).

In Germany and Switzerland, active assisted suicide – ie a doctor prescribing and handing over a lethal drug – is illegal. But German and Swiss law does allow assisted suicide within certain circumstances. In Germany, assisted suicide is legal as long as the lethal drug is taken without any help, such as someone guiding or supporting the patient's hand. In Switzerland, the law is more relaxed: it allows assisted suicide as long as there are no "self-seeking motives" involved. Switzerland has tolerated the creation of organisations such as Dignitas and Exit, which provide assisted dying services for a fee.

In a recent survey, two-thirds of Germans said they would support a law that enabled active assisted suicide too. But the government has announced it wants to tighten the law around assisted suicide, with the health minister, Hermann Gröhe, stating that he wants to ban organisations like Dignitas in Germany. Philip Oltermann in Berlin

Belgium

 

Belgium passed a law in 2002 legalising euthanasia, becoming the second country in the world to do so. The law says doctors can help patients to end their lives when they freely express a wish to die because they are suffering intractable and unbearable pain. Patients can also receive euthanasia if they have clearly stated it before entering a coma or similar vegetative state.

Assisted suicide is not mentioned in the law, which does not specify a method of euthanasia. As Jacqueline Herremans, president of the Association for the Right to Die with Dignity, says: "We don't make a distinction in the semantics." However, the physician has to be present at the bedside of the patient to their last breath, unlike the Oregon model where the doctor gives only the prescription of drugs.

Belgian euthanasia cases rose to 1,807 in 2013, compared with 1,432 in 2012, 708 in 2008 and 235 in 2003. Just over half of cases last year were aged 70 or over, and 80% of the applications were made by Dutch-speakers.

High-profile euthanasia cases have included a 44-year-old transsexual woman whose botched sex-change operation left her with physical deformities that she felt made her look like a "monster"; and 45-year-old identical twins who were deaf and going blind and believed they had nothing left to live for.

This February, Belgium became the first country to legalise euthanasia for children. There is no age limit for minors seeking a lethal injection, but they must be conscious of their decision, terminally ill, close to death and suffering beyond any medical help. They also need the assent of their parents to end their lives. So far, no such cases have yet been reported to authorities


Assisted Suicide Law In Germany Passes Despite Concerns Over Nazi Association

The German Parliament passed a bill Friday that would allow assisted suicide if it is conducted with “altruistic motives,” the Associated Press reported. The practice is still prohibited if done on a “business” basis.

Lawmakers had been debating the bill for months, and the issue had cut across party lines, bringing out passionate arguments from all sides. For some, discussion of euthanasia recalls Germany’s history in World War II, as the Nazis used the practice to kill more than 200,000 people with mental and physical disabilities.

The final bill passed 360-233, despite arguments that the law’s ambiguous language could leave doctors open to significant legal challenges. The bill allows assisted suicide on an “individual basis out of altruistic motives,” according to the AP, but warns that individuals who offer to help someone with suicide “on business terms” could face up to three years in prison.

Former Justice Minister Brigitte Zypries said the measure “will open an era of great legal uncertainty,” and she is confident it will be appealed to the Federal Constitutional Court.

“When does a doctor behave in a business fashion?” Zypries asked lawmakers, the AP reported. “That is unclear.”

As the issue was debated among lawmakers, Germany’s Jewish community advocated against legalizing assisted suicide. The Central Council of Jews in Germany, the country’s main Jewish organization, said Monday that Germany should not change its laws on the issue, according to the Times of Israel.

Before the passage of the new law, assisted suicide existed in a murky area of German law. Doctors in Germany were allowed to accelerate death for terminal patients by providing high doses of pain medication or by withdrawing life sustaining treatments if the patient asked for this option. However, it was illegal to help a patient kill themselves and fail to alert emergency medical services.

German lawmakers debated four different proposals, with the middle version that passed gaining support from all parties in Parliament, including Chancellor Angela Merkel’s Christian Democrats and the opposition Left Party.

“Seriously ill and elderly people should not be pushed to commit suicide,” Central Council President Josef Schuster, a physician and member of the Central Ethics Committee of the German Medical Association, said in a statement Tuesday, according to the Times of Israel.

Other countries in Europe have previously legalized euthanasia, including the Netherlands, Belgium and, in some cases, Switzerland, according to the Guardian. Five states in the United States also allow doctors to prescribe lethal doses of medication to terminally ill patients, although euthanasia is illegal in the U.S.





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