case,
             the court allowed a competent patient to terminate the use of life-
             sustaining medical machines to prolong life. Since New Jersey's decision,
             all fifty states have enacted similar statutes which contain living will
             provisions. However, although the United States Supreme Court upheld the
             Quinlan decision in re Cruzan , it changed the parameters of passive
             euthanasia . With the Cruzan decision, the Supreme Court held that passive
             euthanasia was legal but only for competent adults or those who are
             incompetent but have previously procured a living will. However, if the
             patient is without a living will and incompetent, it becomes the burden of
             the family to prove that there is "clear and convincing evidence" to the
             affect that the patient does not want to continue living in a vegetative
             state. As to active euthanasia, there has been no Supreme Court ruling
             ...