In fact, however, the Court undermined the distinction when it endorsed terminal sedation.
Terminal sedation seems consistent with traditional medical care but often is a form of euthanasia.
Moreover, it is a practice that is ethically more problematic than assisted suicide or voluntary euthanasia. Although physical pain is almost always treatable, some pain cannot be relieved by analgesia. In response to this concern, hospice providers and other medical professionals assured the Court that even the most severe suffering could be alleviated by sedating the patient into unconsciousness. For a very few patients, however, sedation to a sleep-like state may be necessary in the last days or weeks of life to prevent the patient from experiencing severe pain. With this assurance from the medical profession, Justices Sandra Day O'Connor, Stephen Breyer, and Ruth Bader Ginsburg wrote in their concurring opinions that the case for a right to assisted suicide had not been made.