Quick Facts About Assisted Suicide

By Margaret Dore, Esq.*

For a new print version, suitable for a handout, click here.

1.  Assisted Suicide

Assisted suicide means that someone provides the means and/or information for another person to commit suicide.  When a physician is involved, the practice is physician-assisted suicide.[1]

2. The Oregon and Washington Laws

In Oregon, physician-assisted suicide was legalized in 1997 via a ballot measure.[2]  In Washington State, a similar law was passed via another ballot measure in 2008 and went into effect in 2009.[3]  No such law has made it through the scrutiny of a legislature despite more than 100 attempts.[4]

3.  Patients are Not Necessarily Dying

The Oregon and Washington laws are restricted to patients predicted to have less than six months to live.[5]  Such persons are not necessarily dying.  Doctors can be wrong.[6]  Moreover, treatment can lead to recovery.  Consider Jeanette Hall, who was diagnosed with cancer and given six months to a year to live.[7]  She was adamant that she would "do" Oregon’s law, but her doctor, Ken Stevens, convinced her to be treated instead.[8] She is still alive 12 years later.[9]

4.  A Recipe for Elder Abuse

The Washington and Oregon laws are a recipe for elder abuse. The most obvious reason is due to a lack of oversight when the lethal dose is administered.[10] For example, there are no witnesses required at the death; the death is allowed occur in private.[11] With this situation, the opportunity is created for an heir, or some other person who will benefit from the patient’s death, to administer the lethal dose to the patient without his consent.  Even if he struggled, who would know?

5. Empowering the Healthcare System

In Oregon, patients desiring treatment under the Oregon Health Plan have been offered assisted suicide instead. 

The most well known cases involve Barbara Wagner and Randy Stroup.[12] Each wanted treatment.[13] The Plan denied their requests and steered them to suicide by offering to pay for their suicides.[14] Neither Wagner nor Stroup saw this scenario as a celebration of their "choice." Wagner said: "I'm not ready to die."[15] Stroup said: "This is my life they’re playing with."[16]

Wagner and Stroup were steered to suicide. Moreover, it was the Oregon Health Plan, a government entity, doing the steering.[17]

6. Suicide Contagion

Oregon's suicide rate, which excludes suicides under its physician-assisted suicide law, has been "increasing significantly" since 2000.[18] 

Just three years prior, Oregon legalized physician-assisted suicide. This increased suicide rate is consistent with a suicide contagion. In other words, legalizing one type of suicide encouraged other suicides.  Montana already has one of the highest suicide rates in the nation.[19]

7.  A "Wedge" Issue

In Washington State, where assisted suicide was legalized four years ago, there is already a discussion to expand its law to direct euthanasia for non-terminal people.[20]  Indeed, last March, there was a Seattle Times newspaper column describing reader suggestions for euthanasia for people unable to afford care, which would be involuntary euthanasia.[21]

* Margaret Dore is an attorney in Washington State where assisted suicide is legal.  She is also President of Choice is an Illusion, a nonprofit corporation opposed to assisted suicide.  For more information, see www.margaretdore.com and www.choiceillusion.org 

[1]  Compare: American Medical Association, Code of Medical Ethics, Opinion 2.211, available at http://www.ama-assn.org/ama/pub/physician-resources/medical-ethics/code-medical-ethics/opinion2211.page
[2]  The Oregon and Washington laws are similar.  For a short article about Washington’s law, see Margaret K. Dore, "'Death with Dignity': What Do We Advise Our Clients?," King County Bar Association, Bar Bulletin, May 2009, available at https://www.kcba.org/newsevents/barbulletin/BView.aspx?Month=05&Year=2009&AID=article5.htm
[3]  Id.
[4]  http://epcdocuments.files.wordpress.com/2011/10/attempts_to_legalize_001.pdf
[5]  See ORS 127.800 s.1.01(12) and RCW 70.245.010(13).
[6]  See e.g., Nina Shapiro, "Terminal Uncertainty: Washington’s new "Death With Dignity" law allows doctors to help people commit suicide—once they’ve determined that the patient has only six months to live. But what if they’re wrong?," 01/14/09, available at http://www.seattleweekly.com/2009-01-14/news/terminal-uncertainty 
[7]  See Jeanette Hall, Letter to the editor, "She pushed for legal right to die, and - thankfully - was rebuffed, Boston Globe, October 4, 2011 ("I am so happy to be alive!), available at http://www.boston.com/bostonglobe/editorial_opinion/letters/articles/2011/10/04/she_pushed_for_legal_right_to_die_and___thankfully___was_rebuffed/ Kenneth Stevens MD, Letter to the Editor, "Oregon mistake costs lives," The Advocate, the official publication of the Idaho State Bar, Sept. 2010, (scroll down to last letter at www.margaretdore.com/info/Stevens.pdf ).
[8]  Id.
[9]  Per her telephone call today.
[10]  The Oregon and Washington Acts can be viewed in their entirety here and here.
[11]  Id.
[12]  See Susan Donaldson James, "Death Drugs Cause Uproar in Oregon," ABC News, August 6, 2008, at http://abcnews.go.com/Health/story?id=5517492&page=1; "Letter noting assisted suicide raises questions," KATU TV, July 30, 2008, at http://www.katu.com/news/specialreports/26119539.html ; and Ken Stevens, MD, Letter to Editor, "Oregon mistake costs lives," The Advocate, the official publication of the Idaho State Bar, September 2011, to view, scroll down to bottom of second page here: http://www.margaretdore.com/info/September_Letters.pdf
[13] Id.
[14] Id.
[15] KATU TV at note 12
[16] ABC News at note 12
[17]  See also Affidavit of Ken Stevens MD (Leblanc v. Canada), with attachments, available at http://maasdocuments.files.wordpress.com/2012/09/signed-stevens-aff-9-18-12.pdf 
[18]  See "Suicides in Oregon: Trends and Risk Factors," Oregon Department of Human Services, Public Health Division, September 2010, page 6, ("Deaths relating to the death with Dignity Act (physician-assisted suicides) are not classified as suicides by Oregon law and therefore excluded from this report"), available at http://epcdocuments.files.wordpress.com/2011/10/or_suicide_report_001.pdf
See also Oregon Health Authority, News Release, "Rising suicide rate in Oregon reaches higher than national average," September 9, 2010, ("suicide rates have been increasing significantly since 2000") available at http://www.oregon.gov/DHS/news/2010news/2010-0909a.pdf
[19]  Cindy Uken, "State of Dispair: High-Country Crisis, Montana’s suicide rate leads the nation," Billings Gazetter, November 25, 2012, http://billingsgazette.com/news/state-and-regional/montana/montana-s-suicide-rate-leads-the-nation/article_b7b6f110-3e5c-5425-b7f6-792cc666008d.html?print=true&cid=print
[20]  See Brian Faller, "Perhaps it's time to expand Washington's Death with Dignity Act, The Olympian, November 16, 2011, available at http://www.theolympian.com/2011/11/16/1878667/perhaps-its-time-to-expand-washingtons.html
[21]  See Jerry Large, "Planning for old age at a premium," The Seattle Times, March 8, 2012 at http://seattletimes.nwsource.com/text/2017693023.html ("After Monday's column,  . . . a few [readers] suggested that if you couldn't save enough money to see you through your old age, you shouldn't expect society to bail you out. At least a couple mentioned euthanasia as a solution.")  (Emphasis added).

Oregon Doctor's Letter to Medical Society

I practice internal medicine in Oregon where assisted suicide is legal.  I write to urge you to maintain your policy against physician-assisted suicide and have attached a copy of this letter to this e-mail.  Contrary to marketing rhetoric by suicide advocates, the safeguards do not protect patients.  Please consider my patient’s story below.

I was caring for a 76 year-old man who presented to my office with a sore on his arm, eventually diagnosed as metastatic malignant melanoma.  I referred him to both medical and radiation oncology for evaluation and therapy. I had known this patient and his wife for over a decade. He was an avid hiker, a popular hobby here in Oregon, and as his disease progressed, he was less able to do this, becoming depressed, which was documented in his chart. My patient expressed a wish for doctor-assisted suicide to the medical oncologist, but rather than take the time to address depression or ask me, as his primary care physician, to talk with him, the specialist called me and asked me to be the "second opinion" for his suicide.  I told her that assisted suicide was not appropriate for this patient, but unfortunately, my concerns were ignored, and two weeks later my depressed patient was dead from an overdose prescribed by this doctor. His death certificate listed the cause of death as melanoma.

Updated Quick Facts About Assisted Suicide

By Margaret Dore, Esq.*

For a new print version, suitable for a handout, click here.

1.  Assisted Suicide

Assisted suicide means that someone provides the means and/or information for another person to commit suicide.  When a physician is involved, the practice is physician-assisted suicide.[1]

2. The Oregon and Washington Laws

In Oregon, physician-assisted suicide was legalized in 1997 via a ballot measure.[2]  In Washington State, a similar law was passed via another ballot measure in 2008 and went into effect in 2009.[3]  No such law has made it through the scrutiny of a legislature despite more than 100 attempts.[4]

3.  Patients are Not Necessarily Dying

The Oregon and Washington laws are restricted to patients predicted to have less than six months to live.[5]  Such persons are not necessarily dying.  Doctors can be wrong.[6]  Moreover, treatment can lead to recovery.  Consider Jeanette Hall, who was diagnosed with cancer and given six months to a year to live.[7]  She was adamant that she would "do" Oregon’s law, but her doctor, Ken Stevens, convinced her to be treated instead.[8] She is still alive 12 years later.[9]

4.  A Recipe for Elder Abuse

The Washington and Oregon laws are a recipe for elder abuse. The most obvious reason is due to a lack of oversight when the lethal dose is administered.[10] For example, there are no witnesses required at the death; the death is allowed occur in private.[11] With this situation, the opportunity is created for an heir, or some other person who will benefit from the patient’s death, to administer the lethal dose to the patient without his consent.  Even if he struggled, who would know?

5. Empowering the Healthcare System

In Oregon, patients desiring treatment under the Oregon Health Plan have been offered assisted suicide instead. 

The most well known cases involve Barbara Wagner and Randy Stroup.[12] Each wanted treatment.[13] The Plan denied their requests and steered them to suicide by offering to pay for their suicides.[14] Neither Wagner nor Stroup saw this scenario as a celebration of their "choice." Wagner said: "I'm not ready to die."[15] Stroup said: "This is my life they’re playing with."[16]

Wagner and Stroup were steered to suicide. Moreover, it was the Oregon Health Plan, a government entity, doing the steering.[17]

6. Suicide Contagion

Oregon's suicide rate, which excludes suicides under its physician-assisted suicide law, has been "increasing significantly" since 2000.[18] 

Just three years prior, Oregon legalized physician-assisted suicide. This increased suicide rate is consistent with a suicide contagion. In other words, legalizing one type of suicide encouraged other suicides.  Montana already has one of the highest suicide rates in the nation.[19]

7.  A "Wedge" Issue

In Washington State, where assisted suicide was legalized four years ago, there is already a discussion to expand its law to direct euthanasia for non-terminal people.[20]  Indeed, last March, there was a column describing reader suggestions for euthanasia for people unable to afford care, which would be on an involuntary basis for people who want to live.[21]

* Margaret Dore is an attorney in Washington State where assisted suicide is legal.  She is also President of Choice is an Illusion, a nonprofit corporation opposed to assisted suicide.  For more information, see www.margaretdore.com and www.choiceillusion.org 

[1]  Compare: American Medical Association, Code of Medical Ethics, Opinion 2.211, available at http://www.ama-assn.org/ama/pub/physician-resources/medical-ethics/code-medical-ethics/opinion2211.page
[2]  The Oregon and Washington laws are similar.  For a short article about Washington’s law, see Margaret K. Dore, "'Death with Dignity': What Do We Advise Our Clients?," King County Bar Association, Bar Bulletin, May 2009, available at https://www.kcba.org/newsevents/barbulletin/BView.aspx?Month=05&Year=2009&AID=article5.htm
[3]  Id.
[4]  http://epcdocuments.files.wordpress.com/2011/10/attempts_to_legalize_001.pdf
[5]  See ORS 127.800 s.1.01(12) and RCW 70.245.010(13).
[6]  See e.g., Nina Shapiro, "Terminal Uncertainty: Washington’s new "Death With Dignity" law allows doctors to help people commit suicide—once they’ve determined that the patient has only six months to live. But what if they’re wrong?," 01/14/09, available at http://www.seattleweekly.com/2009-01-14/news/terminal-uncertainty 
[7]  See Jeanette Hall, Letter to the editor, "She pushed for legal right to die, and - thankfully - was rebuffed, Boston Globe, October 4, 2011 ("I am so happy to be alive!), available at http://www.boston.com/bostonglobe/editorial_opinion/letters/articles/2011/10/04/she_pushed_for_legal_right_to_die_and___thankfully___was_rebuffed/ Kenneth Stevens MD, Letter to the Editor, "Oregon mistake costs lives," The Advocate, the official publication of the Idaho State Bar, Sept. 2010, (scroll down to last letter at www.margaretdore.com/info/Stevens.pdf ).
[8]  Id.
[9]  Per her telephone call today.
[10]  The Oregon and Washington Acts can be viewed in their entirety here and here.
[11]  Id.
[12]  See Susan Donaldson James, "Death Drugs Cause Uproar in Oregon," ABC News, August 6, 2008, at http://abcnews.go.com/Health/story?id=5517492&page=1; "Letter noting assisted suicide raises questions," KATU TV, July 30, 2008, at http://www.katu.com/news/specialreports/26119539.html ; and Ken Stevens, MD, Letter to Editor, "Oregon mistake costs lives," The Advocate, the official publication of the Idaho State Bar, September 2011, to view, scroll down to bottom of second page here: http://www.margaretdore.com/info/September_Letters.pdf
[13] Id.
[14] Id.
[15] KATU TV at note 12
[16] ABC News at note 12
[17]  See also Affidavit of Ken Stevens MD (Leblanc v. Canada), with attachments, available at http://maasdocuments.files.wordpress.com/2012/09/signed-stevens-aff-9-18-12.pdf 
[18]  See "Suicides in Oregon: Trends and Risk Factors," Oregon Department of Human Services, Public Health Division, September 2010, page 6, ("Deaths relating to the death with Dignity Act (physician-assisted suicides) are not classified as suicides by Oregon law and therefore excluded from this report"), available at http://epcdocuments.files.wordpress.com/2011/10/or_suicide_report_001.pdf
See also Oregon Health Authority, News Release, "Rising suicide rate in Oregon reaches higher than national average," September 9, 2010, ("suicide rates have been increasing significantly since 2000") available at http://www.oregon.gov/DHS/news/2010news/2010-0909a.pdf[19]  Cindy Uken, "State of Dispair: High-Country Crisis, Montana’s suicide rate leads the nation," Billings Gazetter, November 25, 2012, http://billingsgazette.com/news/state-and-regional/montana/montana-s-suicide-rate-leads-the-nation/article_b7b6f110-3e5c-5425-b7f6-792cc666008d.html?print=true&cid=print
[20]  See Brian Faller, "Perhaps it's time to expand Washington's Death with Dignity Act, The Olympian, November 16, 2011, available at http://www.theolympian.com/2011/11/16/1878667/perhaps-its-time-to-expand-washingtons.html
[21]  See Jerry Large, "Planning for old age at a premium," The Seattle Times, March 8, 2012 at http://seattletimes.nwsource.com/text/2017693023.html ("After Monday's column, some readers were unsympathetic, a few suggested that if you couldn't save enough money to see you through your old age, you shouldn't expect society to bail you out. At least a couple mentioned euthanasia as a solution.")

Assisted Suicide is not Legal in Montana

Assisted Suicide: Not Legal in Montana;

 A Recipe for Elder Abuse and More

By Margaret Dore, July 15, 2011*

A. Introduction

 Proponents claim that physician-assisted suicide is legal in Montana. This is untrue. A bill that would have accomplished that goal was defeated in the 2011 legislature.

Legal physician-assisted suicide is, regardless, a recipe for elder abuse. It empowers heirs and others at the expense of older people.  In Oregon, where physician-assisted suicide is legal, legalization has empowered the Oregon Health Plan to steer patients to suicide.  There are multiple other problems.

B. What is Physician-Assisted Suicide?

 The American Medical Association (AMA) states: "Physician-assisted suicide occurs when a physician facilitates a patient’s death by providing the necessary means and/or information to enable the patient to perform the life-ending act." (AMA Code of Medical Ethics, Opinion 2.211). For example, a "physician provides sleeping pills and information about the lethal dose, while aware that the patient may commit suicide." Id.

 The AMA rejects physician-assisted suicide. Id. Assisted suicide is also opposed by disability rights groups such as the Disability Rights and Education Defense Fund, and Not Dead Yet.

C.  Most States do not Allow Physician-Assisted Suicide

There are just two states where physician-assisted suicide is legal:  Oregon and Washington.  These states have statutes that give doctors and others immunity from criminal and civil liability arising out of a patient's suicide (euphemistically termed "death with dignity").  See e.g. RCW 70.245.190(1)(a).  These statutes were passed via ballot initiatives.  No such law has ever made it through the scrutiny of a legislature.

D.  Current Montana Law

Under current Montana law, assisting a suicide exposes the assister to civil and criminal liability. Doctors and others can be held civilly liable for: (1) causing another to commit suicide; or (2) failing to prevent a suicide in a custodial situation where the suicide is foreseeable.[1]  This latter situation would typically occur in a hospital or prison.[2]  Those who assist a suicide can also be prosecuted for homicide under Mont. Code Ann. § 45-5-102(1).  Doctors, however, have the right to assert an affirmative defense based on the victim’s consent and other factors. This is due to the Montana Supreme Court decision, Baxter v. State, 354 Mont. 234, ¶¶ 10 & 50, 224 P.3d 1211 (2009).[3]

E. The 2011 Legislative Session

 The 2011 legislative session featured two bills in response to Baxter, both of which failed: SB 116, which would have eliminated Baxter’s affirmative defense; and SB 167, which would have legalized assisted suicide by providing doctors and others with immunity from civil and criminal liability.

During a hearing on SB 167, the bill's sponsor, Senator Anders Blewett, said: "[U]nder current law, .　.　. there’s nothing to protect the doctor from prosecution."[4]

F. Legalization Will Create New Paths of Abuse

In Montana, there has been a rapid growth of elder abuse.[5]  Elders’ vulnerabilities and larger net worth make them a prime target for financial abuse.[6]  The perpetrators are often family members interested in an inheritance.[7] 

In Montana, preventing elder abuse is official state policy.[8]  If Montana would legalize physician-assisted suicide, a new path of abuse would be created against the elderly.  Alex Schadenberg, Chair of the Euthanasia Prevention Coalition, International, states:

"With assisted suicide laws in Washington and Oregon, perpetrators can . . . take a "legal" route, by getting an elder to sign a lethal dose request. Once the prescription is filled, there is no supervision over the administration. . . . [E]ven if a patient struggled, "who would know?"[9]

G. "Terminally Ill" Does Not Mean Dying

Baxter’s affirmative defense applies when patients are "terminally ill," a term that Baxter does not define.  During the Baxter litigation, the plaintiffs offered this definition:

"'Terminally ill adult patient' means '[an adult] who has an incurable or irreversible condition that, without the administration of life-sustaining treatment, will, in the opinion of his or her attending physician, result in death within a relatively short time.'"[10]

This definition is broad enough to include patients with chronic conditions who could "live for decades."  Attorney Theresa Schrempp and doctor Richard Wonderly state:

"[The] definition is broad enough to include an 18 year old who is insulin dependent or dependent on kidney dialysis, or a young adult with stable HIV/AIDS.  Each of these patients could live for decades with appropriate medical treatment.  Yet they are 'terminally ill' according to the definition promoted by advocates of assisted suicide."[11]

H. Legal Physician-Assisted Suicide Empowered the Oregon Health Plan, Not Individual Patients

 Once a patient is labeled "terminal," an easy argument can be made that his or her treatment should be denied. This has happened in Oregon where patients labeled "terminal" have not only been denied coverage for treatment, they have been offered assisted-suicide instead.

The most well known cases involve Barbara Wagner and Randy Stroup. (KATU TV, ABC News).[12]  The Oregon Health Plan refused to pay for their desired treatments and offered to pay for their suicides instead. Neither Wagner nor Stroup saw this as a celebration of their "choice." Stroup said: "This is my life they’re playing with." Wagner said: "I’m not ready to die."

Stroup and Wagner were steered to suicide. Moreover, it was the Oregon Health Plan doing the steering. Oregon’s law empowered the Oregon Health Plan, not individual patients. 

I. In Oregon, Legalization of Physician-Assisted Suicide is Correlated to an Increase in Other Suicides

Oregon's suicide rate, which excludes suicide under Oregon's physician-assisted suicide law, has been "increasing significantly" since 2000.[13]  Just three years prior, in 1997, Oregon legalized physician-assisted suicide. [14]  In Oregon, legalization of physician-assisted suicide is statistically correlated with an increased rate of other suicides.

J.  The Oregon Reports do not Prove That Assisted-Suicide is "Safe"

 During the 2011 legislative session in Montana, proponents claimed that annual reports from Oregon demonstrated the safety of physician-assisted suicide.  These reports do not discuss whether the people who died consented when the lethal dose was administered.  During a hearing on SB 167, Senator Jeff Essmann made a related point, as follows:

"[A]ll the protections [in Oregon’s law] end after the prescription is written. [The proponents] admitted that the provisions in the Oregon law would permit one person to be alone in that room with the patient. And in that situation, there is no guarantee that that medication is self-administered.

So frankly, any of the studies that come out of the state of Oregon’s experience are invalid because no one who administers that drug against – to that patient is going to be turning themselves in for the commission of a homicide."[15]

K.  SB 167 was Defeated in the Senate Judiciary Committee

During the hearing on SB 167, Senator Essman also stated:

"There’s inadequate protection in [SB 167] for the powerless.  It’s our obligation to protect the powerless. . . .  I’m going to vote no."[16]

SB 167, seeking to legalize physician-assisted suicide in Montana, was defeated in the Senate Judiciary Committee.[17] 

L. Conclusion

 Legal assisted suicide is a recipe for elder abuse.  The practice has multiple other problems.  Don't make Oregon's and Washington's mistake.  Keep assisted suicide out of Montana.


*  Margaret Dore is an attorney in Washington State where assisted suicide is legal.  She was an amicus curie in the Baxter litigation.  She testified before the Montana Senate Judiciary Committee against SB 167, which had sought to legalize physician-assisted suicide in Montana.  Her publications include Margaret K. Dore, "Aid in Dying: Not Legal in Idaho; Not About Choice," The Advocate, official publication of the Idaho State Bar, Vol. 52, No. 9, pages 18-20, September 2010.

* * *

[1]   Krieg v. Massey, 239 Mont. 469, 472-3, 781 P.2d 277 (1989). 

[2]  Id.
[3]  To view Baxter, go here.  To view an analysis of Baxter, go here.
[4]  Go here to see a transcript of this quote and other quotes by Senator Blewett. 
[5]  Great Falls Tribune, "Forum will focus on the rapid growth in abuse of elders," June 10 2009 ("The statistics are frightening, and unless human nature takes a turn for the better, they’re almost certain to get worse").  See also Nicole Grigg, Elder Abuse Prevention, Kulr8.com, June 15, 2010 and Big Sky Prevention of Elder Abuse Program, What is Elder Abuse.
[6]  MetLife Mature Market Institute Study:  Broken Trust: Elders, Family, and Finances, 2009. 
[7]  Id.
[8]  See e.g., the "Montana Elder and Persons With Developmental Disabilities Abuse Prevention Act," 52-3-801, MCA; the Protective Services Act for Aged Persons or Disabled Adults, 52-3-201, MCA; and the "Montana Older Americans Act," 52-3-501, et. al., MCA.  Also go here. 
[9]  Alex Schadenberg, Letter to the Editor, "Elder abuse a growing problem," The Advocate, official publication of the Idaho State Bar, October 2010, page 14, available at http://www.isb.idaho.gov/pdf/advocate/issues/adv10oct.pdf. 
[10]  Plaintiffs’ Answer to Interrogatory No. 4, available at page 3, here:  http://www.euthanasiaprevention.on.ca/ConnMemo02.pdf  
[11]  Opinion Letter from Dr. Richard Wonderly and Theresa Schrempp, Esq., to Alex Schadenberg, available here:  http://www.euthanasiaprevention.on.ca/ConnMemo02.pdf
[12]  See Susan Harding and KATU web staff, "Letter noting assisted suicide raises questions," July 30, 2008 and Susan Donaldson James, "Death drugs Cause Uproar in Oregon," ABC News, August 6, 2008.  See also Ken Stevens, MD, "Oregon mistake costs lives," official publication of the Idaho State Bar, September 2010, pages 16-17, available at http://www.isb.idaho.gov/pdf/advocate/issues/adv10sep.pdf ("In Oregon, the mere presence of legal assisted-suicide steers patients to suicide . . . ").
[13]  See Oregon Government News Release, September 9, 2010 ("suicide rates have been increasing significantly since 2000"); and "Suicides in Oregon, Trends and Risk Factors, September 2010 ("Deaths relating to the death with Dignity Act (physician-assisted suicides) are not classified as suicides by Oregon law and therefore excluded from this report").
[14]  See e.g., "Oregon's Death with Dignity Act:  The First Year's Experience," page 1 ("On October 27, 1997, physician-assisted suicide became a legal medical option for terminally ill Oregonians").
[15]  Montana Senate Judiciary Hearing, February 10, 2011, Transcript, p. 15, lines 1 to 11, available here. 
[16]  Id., lines 12 to 14.
[17]  See Montana Legislative website at
http://www.leg.mt.gov/css/default.asp (SB 167 was tabled in Committee on February 10, 2010).