Throughout the twentieth century, major scientific and medical
             advances have greatly enhanced the life expectancy of the average person.
             However, there are many instances where doctors can preserve life
             artificially. In these cases where the patient suffers from a terminal
             disease or remains in a "persistent vegetative state" or PVS from which
             they cannot voice their wishes for continuation or termination of life, the
             question becomes whether or not the patient has the freedom to choose
             whether or not to prolong their life even though it may consist of pain and
             suffering. In answer to this question, proponents of physician-assisted
             suicide, most notably, Dr. Jack Kevorkian, are of the opinion that not only
             should patients be able to abstain from treatment, but if they have a
             terminal and/or extremely painful condition, they should be able to seek
             out the assistance of a doctor in order to expedite their death with as
             little pain as possible. Contained herein are the arguments for and against
             the le galization of doctor-assisted suicide, as well as where the state
             courts stand in respect to this most delicate of issues. In the hopes of
             clarification, we must first distinguish between active and passive
             euthanasia. Passive euthanasia involves the patient's refusal of medical
             assistance. It involves the right to die which is protected by the United
             States Constitution clauses of due process liberty and the right to privacy
             (Fourteenth Amendment). The right to doctor-assisted suicide, or active
             euthanasia, consists of, "...a patient's right to authorize a physician to
             perform an act that intentionally results in the patient's death, without
             the physician's being held civilly or criminally liable for having caused
             the death" . The "passive" form of euthanasia was first deemed legal by the
             New Jersey State Supreme Court in 1976 In re Quinlan . In the Quinlan...