Physician-assisted suicide: new protocol for a rightful death.

concepts not specifically rooted in the Constitution. However, in finding that the New York statutes violate the Equal Protection Clause, the Second Circuit itself seems to expand upon the meaning of "similarly circumstanced," positing a specific meaning to the phrase which cannot necessarily be proven. These two appellate decisions, Compassion in Dying v. Washington and Quill v. Vacco, clearly reveal the problems attendant on this issue which are yet to be fully resolved. Is there a fundamental right to hasten one's death? Can such a right be safely legislated? Is there a meaningful distinction between terminating artificial hydration and nutrition and taking prescribed drugs in a lethal dose? When are terminally-ill patients truly "similarly circumstanced?" What constitutes a rational relationship to a legitimate state interest? In light of the United States Supreme Court's recent resolution of these two cases, what case, if any, would provide a better vehicle to successfully challenge a state statute prohibiting physician-assisted suicide? Finally, will state statutes authorizing assisted suicides prevail against future constitutional challenges? As illustrated in Compassion in Dying and 77. Id. 78. Id. 79. See id. at 730 n.2. 80. Id. at 727. 1998]