Few rallying cries sound more straightforward than the "right to die"-but few are more fuzzy or more misunderstood. This becomes all too evident when comparing the right-to-die decision handed down by the U.S. Ninth Circuit Court of Appeals earlier this month and the New Jersey Supreme Court's decision in the Karen Ann Quinlan case twenty years ago. At different times, the "right to die" has embraced significantly different rights. On March 6, in Compassion in Dying v. Washington State, the Ninth Circuit held that because a Washington state statute prohibiting assisted suicide prevents physicians from providing assistance to competent, terminally ill patients who want to end their lives, the law violates the due process clause of the 14th Amendment. As the author of the majority opinion, Judge Stephen Reinhardt, put it, the Constitution "encompasses a due process interest in controlling the time and manner of one's death-- there is, in short, a constitutionally recognized 'right to die.'"
Kamisar, Yale. "It Started with Quinlan: The Ever Expanding 'Right to Die'." Hum. Life Rev. 22, no. 3 (1996): 33-6.