There are at least two fundamental flaws in the Second Circuit's reliance on Casey for this proposition. That, however, was precisely what the Second Circuit did in this case. In the footnote which accompanies the quoted text, the Second Circuit went on to suggest numerous other ways in which the State of New York could achieve its objectives but still allow assisted suicide. The fact that a state may, if it chooses, seek to achieve its legitimate objectives through other means does not, in any way, establish that the means actually selected are either irrational or arbitrary. See City of Cleburne v. Cleburne Living Ctr.
Suicide is the eighth leading cause of death in the United States.
Studies that examine the psychological background of individuals who kill themselves show that 95 percent have a diagnosable mental disorder at the time of death. A State is entitled to guard against potential abuses in such situations. Middlesex Ethics Committee v. Ethics Reports, Vol.