Europe's Way of Death

The way Terri Schiavo's private tragedy has become a political issue in the U.S. estranges many people in Europe. But Europeans, too, have struggled to find the proper balance between the right to life and the right to die. In 1974, Dutch mother-to-be Ineke Stinissen fell into a deep coma after problems with the anesthetic administered during her caesarean section. A year later, her husband Gerard asked that her feeding tube be removed, seeing no hope of her regaining consciousness. Stinissen's doctors refused on ethical grounds. Amid impassioned public debate, Gerard fought for his wife's right to die until late 1989, when a Dutch court ruled that tube feeding constitutes a medical treatment that can be withdrawn when there is no reasonable chance of recovery. Gerard found another doctor who, after determining that his wife was in a persistent vegetative state (PVS), agreed to remove the tube. Eleven days later, Ineke Stinissen died.

These days in the Netherlands and across much of Europe, divisions over euthanasia have largely healed. Polls in the U.K. and France show up to 80% support for legal changes that would allow patients enduring extreme suffering from a terminal illness to request medical assistance to shorten their lives. "The consensus in the Netherlands is that we don't prolong life just because we technically can," explains Johan Legemaate, legal adviser to the Royal Dutch Medical Association. "When a treatment does not improve the patient's situation, a doctor is obliged to stop it."

By this measure, the Schiavo case is straightforward. The patient has no chance of recovery, her husband has asked for her feeding tube to be removed, and Schiavo's doctors and the Florida state courts have approved that request. In the U.S., though, religion and faith-based politics intervene in a way that baffles Europeans. "It would have been handled very differently in Europe," says Wim Distelmans, chairman of the Federal Commission of Euthanasia in Belgium, where euthanasia is permitted if performed by a doctor after an adult patient clearly states a wish to die. "Because of the politics, it's now impossible to have a sensible debate on the issue in the U.S." Writing in the Times of London last week, foreign editor Bronwen Maddox said the Schiavo case "shows just how emphatically the U.S. and Europe are moving on different paths" on moral and social issues.

The debate in Europe centers less on whether euthanasia is right or wrong than on how to regulate it. Yet there are striking differences in terminology and approach. In the Netherlands, a medical treatment can be terminated when it is no longer "meaningful." In Switzerland, where assisted suicide is legal under certain conditions, euthanasia is still forbidden. In practice, though, voluntary euthanasia — when a doctor ends a patient's life with his or her consent — is common. A 2003 University of Zurich study showed that 7 out of 10 terminally ill Swiss resorted to voluntary euthanasia by, for example, ingesting a lethal dose of drugs or asking to have life-support systems disconnected. The practice remains illegal in France, though a draft "right-to-die" law was passed last November in the National Assembly and will be debated by the Senate later this year. If approved, it will "essentially give permission for doctors to stop treatment," says Dr. Jean Cohen, chairman of France's Association for the Right to Die with Dignity.