On average, intimate partners kill approximately 2,000 Americans every year. According to the Bureau of Justice Statistics (Rennison 2002), spouses, ex-spouses, and other intimate partners were responsible for 42 percent of the homicides of female victims and 9 percent of homicides of male victims for which an offender was determined between 1976 and 2002. Although only 24 percent of all homicide victims during those years were female, 63 percent of the victims killed by intimate partners were female. Although the annual numbers of intimate partner homicides decreased between 1976 and 1998, the percentage of victims who were women increased steadily from 54 percent to 72 percent over this period. Among the many diverse and complex motives for intimate-partner homicide, compassion is the alleged motive in a relatively small but rapidly increasing number of cases each year.
Compassionate homicide is defined as the killing of one individual by another with the stated intention of reducing the physical or mental suffering of the individual who dies. Compassionate homicide is sometimes subdivided into two categories: euthanasia and mercy killing. The term euthanasia is used more frequently in terms of homicides in medical settings and for those that are legally sanctioned. The term mercy killing is used more frequently to describe those homicides that occur outside of medical settings, are carried out in secrecy, and are not legally sanctioned. The distinctions between euthanasia and mercy killing, however, are inconsistent, and the terms are often used interchangeably. Compassionate homicide is considered to be voluntary when the individual who is killed requests or consents to die and involuntary when the individual who is killed does not request or consent to die. Death may result from an act of commission or an act of omission. In most cases, the physical or mental suffering considered to justify compassionate homicide is the result of a terminal disease or chronic disability, but any form of suffering might be considered grounds for compassionate homicide.
Assisted suicide is a distinct but closely related phenomenon. Assisted suicide refers to the taking of one’s own life with the help of another individual. It differs from voluntary compassionate homicide because the individual dies as a result of his or her own actions. For example, assistance may consist of supplying the individual with a lethal dose of medication or a weapon with the knowledge that he or she intends to commit suicide; but actions by an individual that actually result in another person’s death, with or without that individual’s consent, cannot be properly construed as assisted suicide, since they meet the technical definition of homicide. In practice, the line between assisted suicide and compassionate homicide often blurs. Interactions with others influence individual intentions, and the line between assistance and coercion is often unclear. For example, an individual may anticipate that he will instinctively fight for his life even as he states that he wishes to die, and thus asks another person to restrain him if he attempts to remove a suffocating object from his face. Most states have specific laws against assisting in another person’s suicide or counseling another person to commit suicide. Some other states do not have specific laws but prosecute assisted suicide under common law. Oregon permits physician-assisted suicide under specified conditions, and a few other states have no criminal prohibition of assisted suicide as of 2005.
The term acquiescent suicide sometimes has been used to refer to acts of suicide, with or without assistance, in which the individual chooses to die as a result of succumbing to the social influence. This might include the expectations of significant others that the individual should die or the message implicit in some institutional environments that life is essentially over. Although some specific cases may involve violations of other laws, the concept of acquiescent suicide has no standing in criminal law; however, it is an important phenomenon from psychological, sociological, and ethical perspectives. In some cultures, widows may kill themselves to acquiesce to societal expectations of the sacrifice of the widow’s life when the husband dies, as in the Indian custom of Sati. Fear of being forcibly killed by other members of the community or of living in shame in a community that views a widow as immoral for continuing to live may be powerful suicidal influences, even when they have not been overtly expressed. Similarly, the expectation that a person with a disability should die rather than become a burden on family or the state may result in acquiescent suicide. Intimate partners sometimes exert incredible dominance and control, particularly in abusive relationships. The ultimate expression of submission to this kind of dominance may be an acquiescent suicide on command of the dominant partner.
In most places, both assisted suicide and compassionate homicide are illegal acts. Some forms of assisted suicide and euthanasia, however, are permitted in Oregon, the Netherlands, Belgium, and a few other jurisdictions. In addition, the U.S. Supreme Court has determined that while there is no constitutional right to assisted suicide, states may pass laws permitting and regulating assisted suicide. Finally, courts have endorsed some forms of compassionate homicide, such as withholding life-prolonging treatment from an individual who is close to death or who makes a competent choice to refuse treatment, even where compassionate homicide and assisted suicide have otherwise been prohibited. In addition, various actions that meet the technical definitions of compassionate homicide or assisted suicide are tolerated in many countries, in spite of the fact that they are officially criminal offenses.
Advocates for assisted suicide and compassionate homicide argue that people should be able to exercise choice about when to die, that the criminalization of these acts results in unnecessary suffering, and that the potential for abuse and error can be controlled by procedural safeguards. Critics of these acts suggest that the potential for error and abuse is too high and impossible to adequately control, that in many cases the individuals who are killed do not request or consent to die, and that suicide is typically an irrational act. Critics argue that legalizing the killing of other human beings based on intentions invites abuse, while advocates argue that society already justifies some killings based on intention in the case of self-defense.
The intent of people who engage in compassionate homicide or assisted suicide is often unclear and subject to conflicting interpretations. For example, in one case, staff members who killed nursing home patients were defended as acting from compassion to end the patients’ suffering. Evidence presented at trial, however, indicated that they chose their victims based on the first letter of their last names, not based on suffering or compassion. Criminal profilers suggest that the real intentions of mercy killers are often very different from the stated intentions of relieving suffering. The Crime Classification Manual, a handbook for criminal profiling and forensic psychology, classifies these acts as ‘‘Mercy Homicide (s).’’ According to these experts:
Death at the hand of a mercy killer results from the offender’s claim/perception of victim suffering and what the offender believes is his or her duty to relieve it. Most often, the real motivation for mercy killing has little to do with the offender’s feelings of compassion and pity for the victim. The sense of power and control the offender derives from killing is usually the real motive. (Douglas, Burgess, Burgess, and Ressler, 1992)
The Manual also points out that mercy killers often go on to commit multiple or serial killings. Since motivations can never be directly observed and behavior is typically the product of multiple and complex factors, it is impossible to determine with certainty what motivational factors are present, the relative importance of various motivational factors, or how these various factors interact in a particular case. In addition, when the person who kills and the person who is killed are members of the same family, many other potential motivations may be present. For example, economic considerations may influence the decision-making process when an inheritance is at stake or when the costs of continued medical care would be substantial.
Humphry and Wickett (1990) present a history of mercy killing from their perspective as advocates for compassionate homicide and assisted suicide. They analyzed 151 cases of euthanasia and defined mercy killing as the taking of a loved one’s life to relieve suffering. These cases typically involved husbands killing wives and occasionally wives killing husbands. Many of these spousal cases involved double suicides or murder-suicides, and those cases involved almost exclusively husbands and wives. Humphry and Wickett reported that in more than 80 percent of euthanasia cases, a dominant male partner killed a spouse and that the most frequent method of killing was firearms. They suggest that the demands of caring for a spouse with a severe illness or disability may be too great and that the killing of a spouse may function as much to release the caregiving spouse from the burden of care as to release the individual who is ill or disabled from further suffering. This suggests an obvious potential conflict of interest when mercy killing or assisted suicide occurs within a spousal relationship and raises questions about when spousal euthanasia serves as a convenient rationale for common murder or a vulnerable partner being driven to suicide.
Other analyses have confirmed the finding that more women than men die by assisted suicide, and women usually are assisted to die by men. This finding is particularly striking considering that women are likely to be younger than their spouses and are typically in better health for their age. Some analysts suggest that when women are no longer viewed as valuable sexual partners because of their age or as efficient homemakers because of their illness or disability, they are disposed of as having outlived their usefulness. Osgood and Eisenhandler (1994) present an analysis of assisted and acquiescent suicide from the perspective of suicidology. They suggest that gender issues and the lack of reasonable alternatives play important roles. In their view many women are more vulnerable to assisted suicide because they are often economically dependent on men, dominated by their male partners, and encouraged by society to view their own value as a function of their ability to take care of others. This gender analysis suggests that wives typically assist their husbands who are ill or disabled by taking care of them, but husbands typically assist their wives who are ill or disabled by encouraging them or assisting them to die.
Nevertheless, it should be pointed out that many feminists are strong supporters of an individual’s right to die at a time of one’s own choosing and of legalization of assisted suicide and euthanasia. For many women, the right to choose how and when to die and the right to choose death to avoid mental or physical suffering are extensions of the principle of choice and control over their own bodies and lives.
Many cases of assisted suicide and compassionate homicide have been at the center of considerable controversy. The following cases received a great deal of public and media attention for a variety of reasons, and subsequently had influence on the public debate. The cases presented here were chosen, in part, to represent the diversity of circumstances and attributes of cases of spousal euthanasia and assisted suicide. It should be noted that the cases that attained the highest profiles are not likely to be typical of the cases that occur most frequently. Cases typically gain high profiles because the individuals involved are already famous, because the alleged offenders are charged, or because they become the subject of a book or play. Only a tiny minority of cases involve people who are already famous or have books written about them, and in many cases, no one is ever charged or the case is dismissed before trial. Many others are settled by plea agreements. Of cases that do reach trial, a few lead to murder or manslaughter convictions with prison sentences, and a few result in acquittals. Most appear to end in convictions for crimes other than murder, with suspended sentences or probation.
In 1920, Frank C. Roberts was charged in Michigan for poisoning his wife Katie Roberts, who had multiple sclerosis. He pleaded guilty and was sentenced to life in prison. He appealed, however, arguing that he had only assisted his wife by preparing the poison, which she drank willingly. Since she had died as a result of suicide, he argued that he could not be an accessory to suicide because suicide was not a crime in Michigan. The court heard arguments that the law that treated assisted suicide like murder was antiquated and cruel. The Michigan Supreme Court, however, upheld the sentence, since Roberts had been charged with and pled guilty to murder, not accomplice to suicide, for his part in his wife’s death.
The Roberts case may have been the first American trial over assisted suicide, and it received widespread national and international attention. Wolfgang Liebeneiner’s film I Accuse (Ich klage an) (1941) presented a trial with obvious parallels to the Roberts’ trial. In the film, a loving husband is tried for murder because he reluctantly poisoned his wife, who had multiple sclerosis. It ends with the husband accusing society of being the real criminals for enforcing an outmoded law that results in unnecessary suffering. I Accuse received international acclaim, including a gold medal at the Venice Film Festival. Long after the end of World War II, Liebeneiner (1965) remained adamant that ‘‘I Accuse . . . was no Nazi propaganda film, but on the contrary a document of humanity in an inhuman time’’ (p. 149). Nevertheless, most experts consider this film to have been among the most sophisticated tools of Nazi propaganda, intended to promote public acceptance for the massive Nazi euthanasia program that exterminated approximately 275,000 people with disabilities and eventually evolved into the Holocaust.
In 1958, author Lael Wertenbaker published Death of a Man, describing how she helped her husband, who had cancer, kill himself in France. The book received considerable attention and was made into a Broadway play called A Gift of Time in 1962. The play, starring Henry Fonda and Olivia de Havilland, brought more attention to the topic. Death of a Man was the first of a series of autobiographical accounts of assisted suicides, and also provides an example of a wife participating in the death of a husband, which occurs less frequently than husbands participating in the deaths of their wives.
In 1983, novelist, social critic, and euthanasia advocate Arthur Koestler, who was seventy-seven years old and had Parkinson’s disease and leukemia, committed suicide. He indicated that he did not want to continue to live in a debilitated state. His third wife, Cynthia, who indicated that she could not live without him, committed suicide along with him, though Cynthia was twenty-one years younger and healthy. At the time, even some advocates for compassionate homicide raised concerns over her willingness to follow her husband to the grave. Critics of compassionate homicide and assisted suicide viewed Cynthia Koestler’s death as an acquiescent suicide, imposed on her by the expectations of others. Some feminists saw this act as a variation of the Indian custom of Sati, in which widows immolate themselves on their husband’s funeral pyre, the ultimate expression of a belief system in which women are valued only as caregivers for their husbands. In their view, Koestler had treated his wife and the family dog—which he also killed when he committed suicide—in much the same way. This concern over whether Cynthia Koestler’s death was truly voluntary was exacerbated some time after Koestler’s death when there were a number of accusations that Koestler had been a repeated rapist who enjoyed battering and bullying women. Koestler was quoted as saying that he carefully selected women he could dominate and control: ‘‘I always picked one type; beautiful Cinderellas, infantile and inhibited, prone to being subdued by bullying’’ (in Cockburn 1998, p. 9). Nevertheless, others argued that Cynthia Koestler was an intelligent adult who made an autonomous choice to die and that her choice should be respected rather than questioned or demeaned. From this perspective, suicide should be respected as an autonomous and rational act for avoiding mental as well as physical suffering, and grief or loneliness are presented as equally valid reasons for suicide as are illness or disability.
In 1985, Roswell Gilbert killed his wife, Emily, who had Alzheimer’s disease. He shot her once in the head at close range, but when she didn’t die he went to get another bullet, reloaded, and shot her a second time. The couple had been married for fifty-one years when he killed her. Many people and most published stories suggested that this was an act of love by a devoted husband, but others raised questions about his motivation, suggesting that he simply wanted to rid himself of the responsibility of caring for an ailing wife. While there was no question about the fact that Emily Gilbert had needed care due to her Alzheimer’s disease, she was not yet in a state of severe debilitation, and she was certainly not in a terminal state. In the end, Gilbert was convicted of murder by a Florida jury and sentenced to seventy-five years in prison with a requirement to serve twenty-five years before being considered for parole. He was granted clemency and released in 1990, and died in 1994.
Derek Humphry and Ann Wickett, who cofounded the Hemlock Society and collaborated as authors on a number of works advocating for the acceptance of assisted suicide and euthanasia, were also at the center of their own controversy. Humphry participated in the death of his first wife, who had breast cancer, helping her commit suicide in 1975. Ann Wickett helped Humphry write Jean’s Way, an emotionally wrenching account of his wife’s illness and suicide that portrayed assisted suicide in a very positive light. Subsequently, Ann Wickett and Derek Humphry married, but after Wickett developed breast cancer and underwent surgery in 1989, she claimed that Humphry was trying to coerce her to commit suicide. Humphry and Wickett parted ways. In the midst of the bitter dispute, Wickett claimed that Humphry had actually murdered his first wife, and Humphry claimed that Wickett had been responsible for her parents’ deaths. Formerly an advocate for assisted suicide and euthanasia, Wickett recanted much of her previous support for the ‘‘right to die’’ and joined forces with anti-euthanasia advocates before killing herself at age forty-nine with a drug overdose and leaving a note blaming Humphry for driving her to suicide. Humphry claimed that she was simply mentally unbalanced.
In 1997, in a case that clearly tested the limits of the mercy-killing defense, Gaye Elisabeth Lock was beaten to death with a hammer by her husband, Peter Lock, who then ransacked the house in an attempt to blame the crime on an intruder. Although Gaye Lock was not ill or disabled and the brutal nature of the murder did not convey an act of compassion, her husband’s lawyer and a psychiatrist defended his actions as a mercy killing. They argued that Lock knew that his wife would be severely distressed when she found out that he had failed to file her tax returns for her. Rather than allow her to suffer, he acted out of compassion. While admitting that his thinking was distorted, they argued that his intentions were compassionate even if his reasoning was faulty. This rationale attempted to present two choices: (1) to accept Lock’s actions as reasonable acts of compassion, or (2) to assume that his belief that he was acting compassionately was so unreasonable that he could not be fully responsible for his actions. Some members of the jury may have agreed with the former or latter view, since the trial ended with a hung jury. A second jury convicted Lock and sentenced him to a mandatory life sentence. The court of appeal ordered a third trial. In the end, the prosecution withdrew the murder charge and accepted a plea of manslaughter with a maximum of eight years in prison.
No case has received more attention than that of Michael and Terri Schiavo. Unlike most previous cases, this case did not involve the determination of whether actions already carried out should be viewed as criminal; it involved determining whether the husband should be empowered to act on his wife’s behalf to end her life by having her life-sustaining feeding tube removed. The bitter battle between Terri Schiavo’s parents, who wanted to preserve her life, and her husband, who wanted to end it, was reflected in parallel debate in the media and by the public. There were only a few facts that both sides agreed upon. In 1990, Terri Schiavo, who was twenty-six years old, experienced a cardiac arrest. The cardiac arrest seemed to be caused by a potassium imbalance, but there was some uncertainty about exactly what caused the imbalance. Paramedics, who considered the situation unusual, called police, who found no evidence of a crime. Terri Schiavo sustained severe brain damage and never fully regained consciousness. While there was some disagreement about the degree of her impairment, there was no doubt that she was severely impaired and totally dependent on others for care, which included tube feeding. In June 1990, her husband, Michael, was appointed guardian without any objection from other family members. In November 1992, the court awarded more than $1,000,000 for medical malpractice to Michael and Terri Schiavo. During the trial, Michael Schiavo indicated his willingness to care for and seek rehabilitation for his wife. By February 1993, however, Michael Schiavo and Terri Schiavo’s parents were engaged in conflict. In May 1998, Michael Schiavo petitioned to have his wife’s feeding tube removed to bring about her death. Between that time and Terri Schiavo’s death on March 31, 2005, there were repeated court decisions, administrative interventions, and even the creation and nullification of special laws. In the end Michael Schiavo had the phrase ‘‘I kept my promise’’ inscribed on his wife’s grave marker. For those who see him as a hero determined to fulfill a promise to his wife, these words are inspiring; for those who view him as a villain determined to control his wife’s destiny, the words are chilling.
This case, like most others, is hinged on intentions. One side considered Michael Schiavo to be a loving husband, who acted with the best of intentions to carry out his wife’s directions not to prolong her life in a state of extreme dependency. From this perspective, who would be better able to make this difficult decision than a loving husband? The other side considered Michael Schiavo as acting from selfish motives to dispose of a wife he now considered to be burdensome. From this perspective, who would be a worse choice to hold the power of life or death over a woman than a ‘‘husband’’ who has moved on to live with and have children by another woman? Each side could summon indirect evidence that seemed to support its view. Intentions, however, are never directly observable, and wherever the truth lies in this particular case, a general assumption of best or worst intentions applied to all cases will always produce errors.
All of these cases are characterized by ambiguity about intentions and assumptions about whose lives are worth preserving and whose lives would be better ended. There is simply no way for society to allow spouses to exercise control of life or death over each other for the best of purposes without providing an easy mechanism for concealing the worst intentions.
A Disability Rights Perspective
While some individuals with chronic illnesses, terminal illnesses, or disabilities have chosen death by assisted suicide or advocated in favor of assisted suicide, most disability rights organizations and leaders have taken strong positions against assisted suicide and various forms of compassionate homicide. There are a number of reasons for this opposition. First, they believe that there is and can be presented considerable objective evidence of widespread social bias against people with disabilities. They believe that decisions to end the lives of people with disabilities will inevitably be influenced by this bias. The simple assumption that most members of society believe that severe disability or illness may be a legitimate reason for killing someone out of compassion, while other real and imagined sources of suffering (e.g., poverty, racial discrimination, loneliness) are not, probably reflects this bias. Second, they believe that permission to choose death will inevitably lead to undue influence to choose it. This undue influence may come from spouses, the health care system, health insurance companies, or society in general. Third, they believe that spouses and others who might make the decisions to end the lives of people with disabilities are often in a conflict of interest. For example, a husband who has been taken care of by his wife for most of his adult life and is confronted with caring for her may have difficulty discerning whether she would not want to go on living like this or whether he does not want to go on being a caregiver.
Finally, many people with acquired disabilities, such as spinal cord injuries, point out that the initial adjustment period is difficult, and that they had times when they would have chosen suicide; but having survived that initial adjustment, however, they are thankful that they were not assisted or encouraged to end their lives. They feel that legitimizing this option would not only have left them vulnerable to the misdeeds of others, it may have led to a catastrophic mistake at their most vulnerable moment.
Beyond the advocacy leadership for people with disabilities, however, support for physician-assisted suicide among people with disabilities is more variable. Gill and Voss (2005), for example, found that among a sample of people with a wide variety of disabilities, attitudes toward legalization of physician-assisted suicide were only slightly less positive than those in the general population, with the majority favoring legalization. Among a subsample with multiple sclerosis, however, a group considered to be particularly likely to personally face issues regarding life or death, support for legalization was much lower, although even in this group 41 percent approved of legalization. Support was much lower among women than among men with disabilities and much lower among African Americans and Hispanics than among whites. These findings are consistent with some general trends.
These trends suggest that many people see potential benefits and also potential risks. They can imagine that there might be some circumstance in which life is so painful or unpleasant that they would prefer a seemingly ‘‘easy’’ death. They can also imagine circumstances in which they might be driven or manipulated toward death, or even simply murdered. If they focus on the possible benefit and ignore the risks, compassionate homicide appears an attractive option. If they focus on the risks and ignore the benefit, so-called compassionate homicide appears to be a deadly pretense for murder. Not surprisingly, the people who have been socially and economically advantaged feel confident about managing the risks. People who have been disadvantaged socially and economically worry more about the risks. People who are healthy and able-bodied assume that they would prefer death to disability and dependency. Research clearly demonstrates, however, that people with disabilities value their lives and rate their quality of life just as high as people without disabilities. To men and women who have always had strong, loving relationships with their spouses, the knowledge that their spouses can end their lives if they become debilitated may be a source of comfort. For millions of other women or men who have been bullied or abused by a spouse, giving that spouse the power of life or death over them is a potential nightmare.
From a disability rights perspective, society’s willingness to see the killing of a spouse with a disability as an act of love while seeing other spousal killings as ultimate acts of domestic violence is a clear reflection of social devaluation. All people suffer, and many things can have a negative impact on one’s quality of life. Many people suffer as a result of poverty, discrimination, addictions, abuse, social isolation, homelessness, stress, depression, and a variety of other causes. If compassionate homicide is a legitimate alternative for addressing quality of life issues related to disability, it is a legitimate response to issues related to these other threats to quality of life. From the disability rights perspective, assisting suicide of people with disabilities while engaging in suicide prevention for others is a subtle form of extermination.
Intimate Partner Violence and Disability
In addition to intimate partner homicide, which was discussed previously, nonlethal intimate partner violence is extremely common. It produces a vast number of injuries, many of which lead to significant disabilities. In the United States, there are approximately 1,000,000 victims of nonlethal domestic violence reported each year, and researchers estimate that there are an additional 3,000,000 unreported victims each year. About 85 percent of these victims are women. Approximately 25 percent of all women report that they have been victims of intimate partner violence at some time during their lives, although the percentage varies from 18 to 50 percent in various studies. The percentage of men reporting domestic violence in various studies varies from about 10 to 25 percent.
Approximately 63 percent of women who report intimate partner violence have physical injuries, but the number of these injuries resulting in long-term disabilities is unknown. Violence is identified as the cause of approximately 20 to 30 percent of all spinal cord injuries and 10 to 20 percent of brain injuries. In addition, people who sustain brain injuries as a result of violence typically are left with more severe disabilities and encounter more difficulties in rehabilitation. Women who experience intimate partner violence are also more likely to suffer from depression and to have suicidal ideation. Women who have been victims of intimate partner violence report significantly lower quality of life and significantly higher rates of impaired physical health than women who have no history of victimization by an intimate partner. Regardless of the cause of their disabilities, women and men with disabilities are more likely to be abused than women and men without disabilities.
This tangle of relationships between violence and disability has important implications for so-called spousal mercy killings and assisted suicides. Even if one could assume that these killings always took place within the context of a healthy and loving marriage, issues of intentions would be difficult to assess. If one is to believe these statistics that emerge reliably from a large body of research, however, one is forced to conclude that many mercy killings, assisted suicides, and acquiescent suicides occur within the context of preexisting family violence and that some will be committed by spouses whose previous violent attacks caused the disability of the spouse that he or she so compassionately eliminates.
Compassionate homicide and assisted suicide often occur in the context of spousal relationships. In the majority of cases, husbands kill wives, but in a significant minority of cases, wives kill husbands. These cases can be presented as the loving acts of spouses who cannot allow their beloved partners to continue suffering or who reluctantly assist their spouses to die when they have come to a rational decision to do so. The same cases can be presented as the cold-blooded crimes of spouses who use the convenient fact of their partner’s illness or disability to conceal their crimes as acts of mercy or who drive a vulnerable spouse to suicide. It is likely that the truth behind some cases lies close to one extreme, the truth behind some others lies at the other extreme, and the truth behind many lies somewhere between these extremes.
- Annas, G. J. ‘‘Physician-Assisted Suicide—Michigan’s Temporary Solution.’’ New England Journal of Medicine 328, no. 21 (1993): 1573–1576.
- Cockburn, A. ‘‘Beat the Devil: The Rapist and the Snitch.’’ The Nation 267, no. 17 (1998): 9.
- Gill, C. J., and L. A. Voss. ‘‘Views of Disabled People Regarding Legalized Assisted Suicide Before and After a Balanced Informational Presentation.’’ Journal of Disability Policy Studies 16 (2005): 6–15.
- Humphry, D., and A. Wickett. The Right to Die: An Historical and Legal Perspective of Euthanasia. Eugene, OR: The Hemlock Society.
- Liebeneiner, W. Letter. Nazi Cinema. New York: Macmillan Publishing, 1965, pp. 149–151.
- ‘‘Lifetime and Annual Incidence of Intimate Partner Violence and Resulting Injuries—Georgia, 1995.’’ Morbidity and Mortality Weekly Report 47, no. 40 (1998): 849–853.
- Marker, A. Deadly Compassion. New York: Avon Books, 1993.
- Oberhardt, M. ‘‘Husband Obsessed by Death and Taxes.’’ Courier Mail, September 11, 2001, p. 5.
- Osgood, N. J., and S. A. Eisenhandler. ‘‘Gender and Assisted and Acquiescent Suicide: A Suicidologist’s Perspective.’’ Issues in Law and Medicine 9, no. 4 (1994): 361–374.
- Smith, W. J. Forced Exit. New York: Times Books, 1997.