Vol. 9 No. 6 (June 1999) pp. 250-252.

EUTHANASIA AND THE RIGHT TO DIE: A COMPARATIVE VIEW by Jennifer M. Scherer and Rita J. Simon. Lanham, MD: Rowman & Littlefield, 1999. 122 pp.

Reviewed by Kathleen M. Hale, J.D., Department of Political Science, Kent State University.

Sherer and Simon have written a book to demonstrate the utility of the comparative approach in the study of domestic euthanasia and end-of life policy. The book is the second in a series which examines issues about which many countries have adopted laws and voiced public opinion, and about which there is considerable media and judicial attention (p. vii). The authors seek also to demonstrate the utility of context, or "sociocultural milieu" (p. vii) in the comparative study of such public policy problems. They have succeeded in demonstrating both the strengths and limitations of comparative contextual analyses in informing domestic policy debates. Euthanasia and the Right to Die: A Comparative View, provides an accessible descriptive narrative of euthanasia and assisted suicide policies placed within the religious, social and legal context of twenty countries.

Sherer and Simon develop a contextual framework against which to consider the primary arguments in favor of active and passive euthanasia, and degrees of physician or other-assisted procedures classified as active voluntary and active involuntary euthanasia. Public policy toward euthanasia and its various permutations is located within the social, legal, and religious contexts of the United States, Canada, the Netherlands, the United Kingdom, Germany, Switzerland, Spain, France, Australia, China, Japan, India, Columbia, South Africa, Iran, Israel, Argentina, Brazil, Italy, and Russia.

The authors select a wide variety of source materials and referents to develop their comparative context; policy analysts will appreciate the vast amount of academic and informal data including Internet citations which are synthesized in Euthanasia and the Right to Die: A Comparative View. Descriptive statistics, influential case histories, identification of organized and influential interest groups, public opinion polls, and statutory developments are blended in narrative fashion with religious demographics and social considerations to describe the allocation of rights and responsibilities across jurisdictions. Social considerations focus on health care financing and systemic or structural issues, with special consideration given to opportunities for exploitation of euthanasia or other end-of-life policies by various constituencies. Potential motivations of stakeholders in private care systems are contrasted with those of public care systems for many of the countries included in the book. The widely divergent legal and social roles of physicians and of palliative practices are described, and leading organizations in the right-to-die movement are identified for many countries along with a description of their roles and activities in shaping the debate.

Euthanasia and the Right to Die: A Comparative View begins with a brief historical perspective of the views of classical and religious scholars regarding life and death, and traces the shift in dialogue from its academic origins to its current political context (p. 4). Historic philosophical and religious positions are contrasted with practical considerations and advances in medicine and technology. The second chapter identifies fundamental issues in the right-to-die debate; this section is quite useful for policy advocates and scholars in discerning semantic distinctions between active and passive euthanasia, and degrees of physician or other-assisted procedures as active voluntary and active involuntary euthanasia. The authors examine general arguments supporting the positions most commonly taken by proponents and opponents of euthanasia and assisted suicide. Exploration of the roles of self-determination, mercy, compassion and the treatment of pain reveal a constant tension between rights and responsibilities from the perspectives of patient, physician, family and society.

In the intermediate chapters (3-6), the authors aggregate countries into groups to present a descriptive narrative of the context within which euthanasia and right-to-die policies are considered. The broad reach of these chapters illustrates the strength of the comparative approach, as well as the limitations inherent in developing contextual factors that can be described in any systematic manner across multiple jurisdictions. Vast contextual differences between nations are underscored by inconsistent treatment across the sample and the apparent lack of available data for certain countries; data for Argentina, Brazil, Italy and Russia is particularly sparse. Clarification of the country groupings and selection rationale would further enhance this substantial collection of data.

The contextual factors are developed most completely for the United States, Canada and Western European nations. For the United States alone, extant forms of right-to-die legislation are presented across the fifty states, including legislation affecting physician assisted suicide, living wills and other directives provided in advance of death, and establishment of medical powers of attorney and other agency relationships for facilitation of health care needs (p. 42-46). Although this degree of specificity is not provided for every country in the book, the authors nevertheless demonstrate the utility of the comparative, contextual approach to public policy analysis. Where incorporated, influential case histories provide a media-based framework for practical analysis and further illuminate unique contextual aspects. Public opinion data is similarly enlightening; the inclusion of survey data from a wide variety of constituencies provides multiple platforms for further research, and the variety of questions employed by various constituencies to elicit survey responses bears further study as well.

In the final chapter, Sherer and Simon synthesize this vast body of information to classify each country against a descriptive index of social indicators, including type of legal system, type of health care system, degree of pubic opinion, dominant religion, type of government, life expectancy, and status of law (p. 104-107). The authors offer conclusions about why legislation exists in some countries, and which social indicators support legality, quasi-legality, or illegality, including trends toward self-determination, existence of a civil law system, industrialization, existence of a publicly-funded health care system, public opinion, and relatively high rates of life expectancy. Through this identification of points of contextual convergence across nations, the authors raise salient questions for further empirical research as well.

In examining religious, social, and legal context in a comparative fashion, the authors successfully identify core issues which inform the debate over euthanasia and end-of-life policy: whether and to what degree individuals exercise control over end-of-life activities, the nature of the relationship between patients and assistants in those activities, and the social impact unique to each national context (p.103). Sherer and Simon also provide exemplars of specifications which have been identified as

essential elements of statutory efforts across the countries included in this work (p. 117-118), the discussion of which informs domestic policy analysis and advocacy in a particularly timely fashion.

Despite the limited treatment provided for some countries, this work succeeds not only in its reach to construct a comparative contextual framework and in its synthesis of data from a wide variety of sources, but in its exposition of the public and private facets of end-of life issues. In Euthanasia and the Right to Die: A Comparative Perspective, Sherer and Simon offer an informative contribution to the literature on euthanasia and right-to die policies around the world.

Copyright 1995