Religion

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The Catholic Church flip-flops on 'the vulnerable'. Photo: Donaldytong

The Catholic Church in Australia is reeling from revelations at the Royal Commission into Institutional Responses to Child Sexual Abuse, of a shocking number of cases that have occurred under its ‘pastoral umbrella.’ Yet it presumes to tell the rest of us about the hypothetical moral dangers of assisted dying laws for ‘the vulnerable.’

To add insult to injury, it flip-flops on its stance.

Never mind that the argument is contradicted by evidence

The Church’s favourite argument — already contradicted by scholarly analysis that curiously seems to be of no interest to the Church — is this: if people are given the choice of assisted dying, they will feel compelled to choose it, coerced by doctors, greedy relatives or others; subtly or otherwise.

No matter that health care workers routinely report that relatives usually try and persuade their dying loved one to endure yet another invasive and burdensome treatment; not dissuade them from it.

The flip-flop

If the Catholic Church were indeed genuinely concerned about coercion of ‘the vulnerable,’ then it would equally oppose the right to refuse medical treatment, particularly if the treatment were life-prolonging. But it doesn’t.

If granny might die as a result of refusing a particular medical intervention, then a doctor might persuade her to refuse in order to conserve medical resources. Or greedy relatives might persuade her so that they are relieved of the burden and expense of looking after her and gain earlier access to her estate.

As eminent legal scholar Gerald Dworkin has argued,1 if there’s a theoretical ‘slippery slope’ for assisted dying, it’s the same for the refusal of life-preserving medical treatment.

To hold different positions under the same risks is to flip-flop. That’s especially so when there are numerous safeguards built into assisted dying statutes, but currently few or none for the right to refuse life-preserving medical treatment.

Parallel theoretical risks: refusal of life-saving medical treatment, and assisted dyingThe Catholic Church approves of the theoretical risk of the left-hand course (refusal of life-saving medical treatment), but not of the theoretical risk of the right-hand course (assisted dying) which is lower in practice by virtue of considerably more statutory safeguards.

Local experience confirms risk is theoretical

In my home state of Victoria, where the right to refuse any unwanted medical treatment has been enshrined in statute for nearly three decades (the Medical Treatment Act 1988), how many prosecutions have there been under the Act’s provisions against inappropriate persuasion?

Precisely none. Not a single case. So much for the theory.

It all serves to highlight that the Catholic Church’s only real argument is that it believes that it’s morally wrong to deliberately hasten death. However, it avoids this argument because as a religious tenet, it doesn’t appeal to the masses.

Catholic directives

The Church’s flip-flop about ‘the vulnerable’ is not a one-off accident. Take for example the ‘Ethical and Religious Directives for Catholic Health Care Services’ published by the United States Conference of Catholic Bishops.

The Bishops ‘direct’ that there is no obligation on patients to use disproportionate means of preserving life. They state that disproportionate means are:

“…those that in the patient’s judgement do not offer a reasonable hope of benefit or entail an excessive burden, or impose excessive expense on the family or the community.”

The Bishops further ‘direct’ that:

“The free and informed judgment made by a competent adult patient concerning the use or withdrawal of life-sustaining procedures should always be respected and normally complied with, unless it is contrary to Catholic moral teaching.”

Setting aside the Church’s hubris of dishonouring the patient’s choice if the Church disagrees, it would be theoretically easy for someone to persuade the patient that hope was not reasonable, that the burden would be too great, or that the cost to the family or society would be too high.

Suffering for our God’s (your own) good

On the next page, the Bishops expressly ‘direct’ that:

“Patients experiencing suffering that cannot be alleviated should be helped to appreciate the Christian understanding of redemptive suffering.”

That’s unqualified. So, if you’re atheist, agnostic, Jewish, Hindu, Muslim or even a Christian who believes assisted dying can be appropriate, as a patient in their institutions you are to be persuaded that suffering against your beliefs and wishes is ‘redemptive’ in the eyes of the Vatican’s version of a God.

In Australia in 2009, for the Office for Family and Life in the Catholic archdiocese of Adelaide, Mr Paul Russell argued in News Weekly that “there is a point to suffering” because:

“It’s about the profound connection that each and every life has to the incarnate God … We know that the sufferings we endure well are joined in some mysterious way to the sufferings of Christ.”

Pity any poor soul who doesn’t share Mr Russell’s views. Curiously, there is no mention of this underpinning belief in his anti-assisted dying blog, “HOPE.”

Invalid argument in any case

The Church’s argument that ‘the vulnerable’ will be ‘at risk’ from assisted dying laws — for example in the Victorian Bishops’ recent pastoral letter to the Catholics of Victoria opposing the upcoming assisted dying parliamentary Bill — is itself fundamentally invalid.

That’s because, as I’ve previously explained, it’s a circular argument: a logical fallacy.

Ban yellow socks on Wednesdays
A circular argument: We must ban yellow socks on Wednesdays or the 'vulnerable' will be 'at risk'.
‘The vulnerable,’ by definition are those ‘at risk,’ and will still be so if we wear yellow socks on Wednesdays. Therefore, we should ban such bright footwear midweek — and anything else we happen to oppose — on the same basis.

Might anyone argue that “we must ban religion because the vulnerable will be at risk of succumbing to extreme religious views”?

Will the Church change its mind?

The Catholic Church does change its mind from time to time, though its reforms are glacially slow.

Take, for example, its theory of limbo, a place on the doorstep of hell where, the Church claimed, babies go if they die before they’re baptised: that they’d be prevented from entering heaven. It would be hard to imagine a crueller worry to put into the heads of uneducated new parents.

But in 2007, after centuries of confidently promoting the theory, the Catholic Church decided that it was wrong, and buried it.

Will it change its mind on assisted dying? Maybe, but don’t hold your breath.

Conclusion

The Catholic Church, reeling from its extensive failure to protect our most vulnerable — children — and notwithstanding some good individuals within, still seeks to morally lecture the rest of us with the logical fallacy of how ‘risky’ assisted dying legislation is supposed to be to ‘the vulnerable,’ while flip-flopping in support of refusing life-saving medical treatment under the same theoretical risk.

The Bishops’ rhetoric exquisitely exposes their confected crisis against assisted dying as nothing but religious doctrine draped in faux secular garb… in reality a sheep in wolves’ clothing.

 

References

  1. Dworkin, G, Frey, RG & Bok, S 1998, Euthanasia and physician-assisted suicide, Cambridge University Press, Cambridge, New York. pp.66ff

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The Age reports a 'gloves off' campaign of misinformation

Both the Herald Sun and The Age reported last week that religious anti-assisted dying crusaders are running a 'gloves off' campaign in Victoria.

Religious forces are gathering once again to attempt to thwart the views of the great majority of Victorians in favour of assisted dying law reform.

Matt Johnston in the Herald Sun quoted Paul Russell, a long-term figure in Catholic circles, and Greek Orthodox Bishop Ezekiel, in statements against assisted dying.

Farrah Thomazin in The Age quoted religious stalwarts Margaret Tighe of Right To Life, and the Australian Christian Lobby, in further statements against assisted dying.

The crux of the story is that 'pollsters' claim to have run a survey in Victoria. They refuse to be identified. They refuse to publish their methodology. And they refuse to publish all their results. Enough said.

They cherry-pick an item from their supposed poll to claim that 33% of Victorians who oppose assisted dying will change their vote against a supporting politician at the next election. They neglect to mention that only a tiny minority of Victorians actually oppose assisted dying. Their analysis is astonishingly superficial, even assuming they ran a proper, robust poll and didn't manufacture the numbers themselves.

They then use this tidbit of 'data' to put the fear of electoral defeat into politicians who will soon to face an assisted dying Bill in the Victorian Parliament.

What rubbish. Assisted dying (AD) opponents seem to be utterly shameless in misrepresenting and distorting cherry-picked data to push their religious agenda — which they pretend isn't religious.

The real situation in respect of AD is the exact opposite of their claims as I show in a proper, robust analysis of legitimate data, demonstrating that:

  • A massive 78.9% of Victorians support AD, with only a tiny 8.1% opposed. Strong supporters outnumber strong opponents by more than ten to one.
  • Significantly more supporters of AD believe that law reform is personally important, than opponents believe the status quo (no law) is personally important.
  • At a general election, far more Victorian voters will punish Members who oppose the AD Bill than will punish Members who support it (3.5 to 1 overall, 2.4 to 1 for the Liberal/National Coalition and 6.6 to 1 for Labor).
  • The co-sponsors of Victoria’s 2008 AD Bill were returned with greatly increased majorities (including relative to their party’s overall performance) despite campaigns against them by anti-AD crusaders.

 

You can read the full analysis here.

So that Victorian politicians are not misled, I have forwarded my report to the Victorian Government's Cabinet and other selected members of Parliament.

The only way in which this campaign could be called 'gloves-off' is that opponents, lurking around with their shadowy misinformation, don't want to get bullshit on their mittens. Hands seem to be much easier to wash. And hide.


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Those actively opposing assisted dying laws are Australia's most religious. Photo: Donaldytong

A claim was recently made on ABC’s QandA that at least 70% of Catholics and Anglicans support assisted dying. The claim was challenged and a FactCheck prepared and vetted by scholars. They concluded that some but not all polls supported the statement. I show unambiguously that relevant polls do. I show further, as I have in the past, that opposition is largely associated with Australia's most religious.

Get the full, detailed report here.

Known polls

In 2007, a Newspoll survey found that 74% of Catholics and 81% of Anglicans support assisted dying. The 2016 Australian Election Study (AES), run by scholars at Australian National University, found almost identical rates: 74% of Catholics and 79% of Anglicans. Although a majority of all religious denomination groups support assisted dying, opposition is highest among minor Christian denominations (Figure 1).

adattitudesreligdenomination.gifFigure 1: Attitudes toward assisted dying by major religious denominations
Source: AES 2016. Note: Chr. = Christian

A significant majority of support for assisted dying was also found across all age groups, education levels, income levels, states, and major political party affiliations and religious denominations, with support amongst Australians overall at 77%.

Casting doubt

However, another poll cited in the FactCheck found far less support: the 2011 National Church Life Survey (NCLS). It found just 28% of Catholics and 25% of Anglicans supported assisted dying.

The problem with the NCLS poll is that it didn’t take a valid sample of Australian Catholics and Anglicans. It sampled mostly or only those who frequently attend religious services.

Views vary widely by attendance frequency

Figure 2 shows the level of support amongst the Australian public, by frequency of attending religious services. While just 2.4% of those who never attend religious services oppose assisted dying, 46.1% of those attending at least once a week oppose it.

adattitudesreligiosity.gifFigure 2: Attitudes toward assisted dying by frequency of attending religious services
Source: AES 2016

NCLS poll cannot answer the question

The NCLS results were even more negative than the AES ‘at least once a week’ results. That’s explained by the NCLS methodology. Firstly, occasional attenders were underrepresented, and non-attenders were excluded altogether. Secondly, more church employees (the most deeply committed and aligned with church policies) than others would have participated. Thirdly, responders may have felt pressured to toe the church line because the survey forms were collected by the churches themselves. And fourthly, those who disagreed with the church line would be less likely to participate.

ABC QandA question answered

So we can discount the NCLS poll because it was not suited to answer the question about all Australian Catholics and Anglicans.

On that basis, it is not only reasonable to say that “up to 70% of Catholics and Anglicans support assisted dying,” but to say that “at least 70% of Catholics and Anglicans support assisted dying.”

Religious connections of opposers

But, back to the opposition of assisted dying. AES data shows that 92% of those opposing and 94% of those strongly opposing assisted dying have a religious affiliation (self-identify with a religious denomination) or attend religious services. So, while a tiny minority of opposers had no religious affiliation nor attended religious services, almost all those opposing have a religious connection.

Frequent service attendance entrenches opposition

If we focus in on those who identify with a religious denomination and who disagree with assisted dying, we find that there’s a massive difference in opposition to assisted dying between the ‘at least once a week’ attenders and everyone else (Figure 3).

adattitudesreligiosityopposers.gifFigure 3: Frequency of attending religious services amongst those with a religious affiliation and who disagree with assisted dying
Source: AES 2016

Not only are the majority of opposers weekly religious service attenders, but weekly attenders are more likely to be strongly opposed. This highlights the strong alignment with and commitment to religious teachings, which (with rare exceptions) oppose assisted dying.

If we define the most religious Australians as those who attend religious services monthly or more often and who self-identify with a religious denomination (“Regulars” in Figure 4), and who make up just 15.7% of the population, their attitudes are remarkably more opposed to assisted dying than all other Australians — by a factor of more than eleven to one.

adattitudesregularssum.gifFigure 4: Attitudes by religious service attendance plus denomination affiliation (“Regulars”)
Source: AES 2016

Amongst the 84.3% of Australians who are not “Regulars”, almost all of them (85.7%) agree with assisted dying, and almost none of them (3.6%) disagree.

Demographic differences explained by religiosity

The variation in attitudes toward assisted dying by general demographics is largely explained by religiosity — defined here as ‘the frequency of attending religious services’.

For example, the increased opposition amongst older Australians is explained by their increased religiosity. The same applies to religious denomination affiliation (e.g. Catholics attend services more often than Anglicans), education, urban versus rural residence, and political party first preference.

Religiosity was the only variable that independently explained variations in opposition to assisted dying.

The double whammy — affiliation and attendance

Also informative is the comparison of those with or without a religious affiliation versus those who do and don’t attend religious services. (Australians fall into all four categories.)

Amongst those with no religious affiliation, people who do attend religious services are only slightly less likely (than those who don’t attend) to support assisted dying (-7%), and their difference in attitude is mostly to neutrality.

However, of those with a religious affiliation, people who do attend religious services are significantly less likely to support assisted dying (-27%), and the majority of their difference in attitude is opposition rather than neutrality.

Thus, those more deeply aligned with their religious denomination through service attendance are significantly more likely to oppose assisted dying.

Moderated by personal experience

The 2007 Newspoll study asked respondents if they had personal experience of someone close who was hopelessly ill and had wanted voluntary euthanasia.

Amongst those with no religious affiliation, this personal experience increased support for assisted dying by just 3.7%, because support was already very high: from 90.9% to 94.6%.

However, amongst those with a religious affiliation, personal experience increased support for assisted dying markedly by 15.2%: from 72.4% to 87.6%.

Thus, those attending religious services, yet with close, personal experience of hopeless illness with a desire for assisted dying, were significantly less likely to align with opposed religious doctrine.

The most religious are a small minority

With so much opposition amongst Australia’s most religious, why is overall support for assisted dying so high? It’s because Australia’s most religious are a small minority of the population.

Nearly half (48%) of Australians never attend religious services, two thirds (65%) attend less than once a year or never, and three quarters (75%) attend once a year or less, including never.

Those who attend religious services frequently (weekly or more often) comprise just 12% of the population, while those who attend regularly (monthly or more often which includes the weeklies) comprise 16%.

Religion in Australia has been declining for decades, and the fall is likely to continue (see Appendix A of the full report, here), meaning that support for assisted dying is likely to increase in the future.

Conclusions

I’ve previously demonstrated how all the signatories to a major anti-assisted dying advertisement were deeply connected with religion. The AES and other studies further our understanding of wider public attitudes toward assisted dying in Australia. They show that while a substantial majority of Australians support assisted dying, almost all the opposition to it is connected with religion, particularly amongst the most religious who are a small minority of the population.

Despite the religious connection of those opposed, there is ample, robust evidence that a great majority of Catholic and Anglican Australians support assisted dying, backing the claim made on national television.

Clergy opposing assisted dying are not representing the broader views of their flocks. Perhaps they may not see that as their role, and perhaps this misalignment of attitudes and beliefs is an example of why religion in Australia is declining.

However, reflecting the views of the great majority of the constituency is the role of politicians, who would do well to take note of this robust evidence of a significant majority of support for assisted dying.

Get the full, detailed report here.

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antiassisteddyingadtheageheraldsun14jun08.gif

You only have to look to understand who is campaigning against your right to choose an assisted death in the face of intolerable and unrelievable suffering.

A case in point is a massive advertisement published in both of Melbourne’s daily newspapers: News Corp’s The Herald Sun (right-wing) and Fairfax Media’s The Age (left-wing). The ad was published in 2008 when Victorian MLC Colleen Hartland introduced the Medical Treatment (Physician Assisted Dying) Bill into the State legislature.

The Catholic Archbishop of Melbourne, Denis Hart, also sent the advertisement as a letter to all members of the Victorian Parliament.1

So, who are the advertisement’s signatories? I’ve listed them all in Table 1.
 

Table 1: Signatories to the 2008 Victorian anti-assisted-dying advertisement

Rt Rev. Graham Bradbeer
Moderator, Presbyterian Church of Victoria

The Rev. Fr Graeme A. Michell, FSSM
Parish Priest, Anglican Catholic Parish of St Mary the Virgin, Melbourne

Rev. Ross Carter
Uniting Church in Australia

Pastor Graham Nelson
Senior Pastor, Life Ministry Centre

Rev. Dr Max Champion
National Chair of the Assembly of Confessing Congregations within the Uniting Church in Australia

Rev. David Palmer
Convenor Church and Nation Committee, Presbyterian Church of Victoria

Pastor Mark Conner
Senior Minister of CityLife Church

Rev. Greg Pietsch
President, Victorian District, Lutheran Church of Australia

Dr Denise Cooper-Clarke
Adjunct Lecturer, Ridley Melbourne Mission and Ministry College

Marlene Pietsch
[Director of the Lutheran School of Theology]
Lutheran Church of Australia

Rabbi Dr Shimon Cowen
Director Institute for Judaism and Civilization

Very Rev. Dr Michael Protopopov
Dean - Russian Orthodox Church in Australia

Rev. Megan Curlis-Gibson
St Hilary’s Anglican Church, Kew

Marcia Riordan
Respect Life Office, Catholic Archdiocese of Melbourne

Archbishop Dr Philip Freier
Anglican Church of Melbourne

Metropolitan Archbishop Paul Saliba
Primate of Antiochian Orthodox Archdiocese of Australia, New Zealand & the Philippines

Imam Riad Galil
West Heidelburg Mosque
Member of the Victorian Board of Imams

Bishop Peter Stasiuk CSSR DD
Eparchy of Saints Peter and Paul of Melbourne, for Ukrainian Catholics in Australia and New Zealand

Rev. Father James Grant SSC
Chaplains Without Borders,
Melbourne Anglican Diocese

Dale Stephenson
Senior Pastor Crossway Baptist Church

Assoc. Professor Afif Hadj MB BS (Melb) FRACS
Director of Surgery, Director of Medical Training, Maroondah Hospital (A Monash University Teaching Hospital)

Pastor Peter Stevens
Victorian State Officer
Festival of Light Australia

Archbishop Denis Hart
Catholic Archdiocese of Melbourne

Dr Nicholas Tonti-Filippini
Associate Dean, JPII Institute for Marriage and Family Melbourne

Rev. Fr Geoff Harvey
Priest of the Good Shepherd Antiochian Orthodox Mission Parish, based at Monash University

Rob Ward
Victorian State Director Australian Christian Lobby

Assoc. Professor Rosalie Hudson
Aged Care & Palliative Care consultant/educator

Jim Zubic
President of Orthodox Chaplaincy Association

Peter McHugh
Senior Pastor Christian City Church, Whitehorse

Persons in blue: Career is religion

 

Almost all of them are religious by career

To save you a lot of time assessing who these people are, I’ve coloured in blue all the folks whose job it is to espouse religion — at least, their own hierarchy’s view of it.

That’s 27 of the 29 signatories who by career are intensely immersed in their own religious perspective of the world; established and promoted through institutional doctrine.

But what about the other two?

What about the other two signatories, Assoc. Prof. Afif Hadi and Assoc. Prof. Rosalie Hudson (in yellow)?

Notice that Prof. Afif Hadi’s entry lists only his surgery profession. Highly relevant, but not mentioned, is that he was President (previously Vice Chairman) of the Australian and New Zealand Board of Trustees, Antiochian Orthodox Archdiocese of Australia and New Zealand. As head of the Board of the Archdiocese, his religious signature is intimately entwined with another: Metropolitan Archbishop Paul Saliba, the Primate of the Antiochian Orthodox Archdiocese.

Assoc. Prof. Rosalie Hudson’s listing too, mentions only seemingly secular links. What is omitted is that she is or was Chair of the University of Divinity (a multi-faith religious institution) Human Research Ethics Committee, Secretary of the Uniting Church’s committee on bioethics, a member of the Interfaith Committee, and an Academic Associate at Charles Sturt University’s School of Theology.

Thus, both Prof. Hadi and Assoc. Prof. Hudson are also deeply rooted in religious faith. The point is not to make any criticism of their faith or practice, but merely to observe the deeply religious connections to opposing assisted dying law reform. It’s worth mentioning that both Hadi and Hudson do valuable charity work.

So, all of them are deeply religious

A pertinent question to ask is: ‘What proportion of the signatories are neutral, scholarly researchers who have studied the empirical evidence from jurisdictions where assisted dying is already lawful?’ Answer: None of them. Enough said.

And what proportion of the signatories to this anti-assisted dying advertisement are very deeply invested in organised religion? The simple answer is as usual: 100%, all of them.

Disconnected from their flocks

Critically, these career-religious fail to reflect the views of their own flocks. We know from repeated polls, for example, that three out of four Australian Catholics, more than three out of four Uniting Church members, and four out of five Anglicans (Church of England) support assisted dying law reform.

How have the religious hierarchy become so out of touch? Perhaps Mr Ian Wood, co-founder of Christians Supporting Choice for Voluntary Euthanasia might be able to offer his own insights.

This kind of clerical disconnect from the contemporary will of the people is one of the key reasons Australians are deserting religion in droves, as successive censuses show.

Conclusion

The evidence is irrefutable. Those who are actively organised to oppose your right to choose an assisted death are deeply religious, even when they use seemingly secular arguments (more on those later).

They are entitled to their opinions for themselves. But what right do they have to deny the vast majority of Australians, who do not agree with their views, the right to choose?

To phrase it in the personal, why does the Catholic Archbishop of Melbourrne, Denis Hart, think it appropriate to demand that Mr Geoff Drummond, a Buddhist, should have suffered against his will at the end of life for the Archbishop's version of faith, rather than Mr Drummond's own spiritual beliefs? Why does Rabbi Shimon Cowen think it appropriate to demand that Mr Alan Rosendorff, a fellow Jew, should have suffered against his will at the end of life for the Rabbi's version of faith, rather than Mr Rosendorff's own carefully-considered and deeply-held views? And why does Imam Riad Galil think it appropriate to demand that Mr Peter Short, not a Muslim, should have suffered against his will at the end of life for the Imam's beliefs, rather than his own?

Perhaps hubris remains alive and well amongst religious conservatives?

-----

Declaration: In fairness to those mentioned in this article, I openly declare that I am agnostic.

 

References

  1. Bradbeer, G, Rt Rev., Carter, R, Rev., Champion, M, Rev. Dr, Conner, M, Pastor, Cooper-Clarke, D, Dr, Cowen, S, Rabbi Dr, Curlis-Gibson, M, Rev., Freier, P, Archbishop Dr, Galil, R, Imam, Grant SSC, J, Rev. Fr, Hadj, A, Assoc. Prof., Hart, D, Archbishop, Harvey, G, Rev. Fr, Hudson, R, Assoc. Prof., McHugh, P, Michell, GA, Rev. Fr, Nelson, G, Pastor, Palmer, D, Rev., Pietsch, G, Rev., Pietsch, M, Protopopov, M, Very Rev. Dr, Riordan, M, Saliba, P, Metropolitan Archbishop, Stasiuk, P, Bishop, Stephenson, D, Stevens, P, Pastor, Tonti-Filippini, N, Dr, Ward, R & Zubic, J 2008, Reject physician assisted dying - An open letter to Victorian MPs, Catholic Archdiocese of Melbourne, viewed 13 Jun 2008, http://www.cam.org.au/Euthanasia.aspx.

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St Patrick's Cathedral, Melbourne, Australia. Photo: Donaldytong

Against current moves to legalise assisted dying, Australian Catholic Father John George invokes Nazi Germany, resorts to ad hominem attacks to dismiss those who disagree with him, and demands that the Pope’s edicts are binding on everyone regardless of their own faith or world view.

On 24th September 2016, Journalists Greg Brown and Rick Morton published an article in The Australian, Victorian coroner credited with turning tide on euthanasia, summarising recent Australian moves to legalise assisted dying choice.

Catholic Father John George commented on the article online, quoting four sections of the Catholic Church’s catechism that prohibit assisted dying (sections 2276–9).

Pushback

Other readers of The Australian remarked that they respected his view for himself but they had no interest in the Pope’s views given the readers were not Catholic. In fact, repeated polls in Australia have shown that even the great majority of Catholics (three out of four) do not agree with the Vatican on the matter of assisted dying, a matter which Fr George dismisses merely as ‘fickle votes and polls.’

I would remind Fr George that these are not fickle: Australian public opinion in favour of assisted dying choice has been consistently in the majority for now more than four decades.

Fr George further quoted Catholic sources, for example the LJ Goody Bioethics Centre in Perth, Australia, which he failed to mention is, literally, an agency of the Catholic Archdiocese of Perth. He also selectively quoted Palliative Care Australia, failing to mention that they have acknowledged that not all pain and suffering can be eliminated at the end of life, even with the best palliative care.

Ad hominem attack

In response to a rising tide of objections to his musings, including from Mr Ian Wood, a fellow Christian and co-founder of Christians for Voluntary Euthanasia Choice, Fr George resorted to the ad hominem attack: to attack the person (or persons) rather than the arguments. He said:

“The pro euthanasia claque here make professional Nazi propaganda expert Goebbels look like a 5th rate amateur.” — Father John George.

For anyone in the dark, a claque is a group of sycophants hired to applaud a performer or public speaker. How rude. Fr George seems to have neglected to reflect that it is he who is hired to promote the performance of the Vatican. I applaud his right to do so, and I do not compare him to a treacherous propagandist in a murderous wartime regime in order to dismiss his arguments: I address the arguments themselves.

Nazi Germany

Fr George makes repeated mentions of Nazi Germany as a core reason to deny assisted dying choice.

In contrast, several years ago I was chatting at a conference with the pleasant and engaging Peter McArdle, then Research Director of the Australian Catholic Bishop’s Conference. He volunteered that he very much disliked the “Nazi Germany” argument so often used in religious circles, and wished it would stop because in so doing it meant they’d already lost the debate.

I agree. It’s a lazy and indefensible argument: that rational people in a functioning democracy must be denied choice for themselves on the basis of what some murderous regime did against others at the point of a gun.

Indeed, to rely on such a standard would be to equally argue against the right to religious practice, because the Catholic Church, through its inquisition practices (medieval C12th, papal C13th, Spanish C15th, Roman and Portuguese C16th) relied on torture and resulted in confiscation of property and at least tens (if not hundreds) of thousands of executions for witchcraft and heresy.

Ultimate hubris

But the real crux is that Fr George then unequivocally demands that:

“Principles elaborated by the pope are universally applicable.” — Father John George.

This ultimate hubris reveals a profound lack of self-reflection, both personally and organisationally. Even entertaining for a moment the premise that one individual (or even organisation) can tell everyone on the planet how they must live their lives, how would we choose that person or organisation? Why is it less valid for the head of any other branch of Christianity, of Judaism, Islam, Hinduism, Buddhism (or any other religion) or an agnostic (which I am) or an atheist, to set such rules for everyone, overriding other deeply-held beliefs and values?

A keener example of ‘blinded by faith’ would be hard to find.

Conclusion

I argue that Fr John George displays some of the gravest hubris of some members of the Catholic church. I respect and applaud his world views for himself and those who wish to subscribe. But using canonincal arguments (that is, religious arguments demanded as universally true by virtue of the supposed authority that dispensed them) is probably a major contributor to the current flight of people away from organised religion.

More happily, such an attitude is also contributing to accelerating the legalisation of assisted dying choice because folks can see these arguments for what they are. For that I doff my hat to Fr George.


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Lyle Shelton's bunkum tweet is broadcast on ABC's Q&A program

The Managing Director of the Australian Christian Lobby, Mr Lyle Shelton, is at it again.

Yesterday, he tweeted ABC's Q&A program as thousands of people do while it is on air. His tweet was broadcast live to air as shown above. What did he say as panelists were discussing assisted dying law reform?

"Sadly voluntary euthanasia quickly became involuntary euthanasia in Holland. #qanda" LyleShelton

Mr Shelton's claim is bunkum.

Confused language

Firstly, he's confused involuntary with non-voluntary euthanasia.

Involuntary euthanasia is the deliberate hastening of the death of an individual in contravention of the express wishes to the contrary of that individual.  Nobody (except the Australian Christian Lobby in its confusion) is seriously suggesting that involuntary euthanasia happens in the Netherlands, even as a 'result' of the country's euthanasia law.

Non-voluntary euthanasia is the deliberate hastening of the death of an individual without an explicit request from that individual. Increased doses of analgesics and sedatives are administered to alleviate intractable symptoms at the end of life, as a result of discussion between doctors and the patient's family (the patient is not currently competent to participate in decisions). The drugs may hasten death and if this happens, life is shortened by hours, or less often, days. Despite claims by some assisted dying opponents that this is unique to the Netherlands, scientific research shows clearly that the practice occurs all over the world and is not 'caused' by voluntary euthanasia laws.

ACL staff sing from the same hymn book

Daniel Flynn, Victorian Director of the Australian Christian Lobby, made a similar claim in a formal submission (#694) to the Victorian Parliament's Inquiry into End Of Life Choices:

"There is sufficient evidence to suggest that involuntary euthanasia is frequent in jurisdictions in which euthanasia has been legalised." [p 4.]

Not a shred—let alone 'sufficient'—evidence was offered to back up this silly myth, though it's hardly surprising given that there isn't any.

What does the evidence actually show?

The scientific evidence is crystal clear and it is the opposite of Lyle Shelton and the Australian Christian Lobby's claim. Since around 1985 the Netherlands had permitted assisted dying by regulation: under agreement amongst relevant authorities. The rate of non-voluntary euthanasia remained relatively unchanged under this arrangement (Figure 1). In 2002 the Netherlands' euthanasia Act came into effect, replacing regulatory arrangements with a comprehensive set of legislative (i.e. statutory) requirements.

 

dutchanduk-nve01.jpg
Figure 1: Netherlands and UK non-voluntary euthanasia rates

Since 2002, the rate of non-voluntary euthanasia in the Netherlands has dropped, not risen.1 The drop is statistically significant. The rate of non-voluntary euthanasia in the Netherlands is now around the same level as in the United Kingdom.2 The UK is generally accepted as the world's gold standard in palliative care practice and it does not have an assisted dying law.

Absolutely contrary to the claim of the Australian Christian Lobby's Lyle Shelton, the rate of non-voluntary euthanasia in the Netherlands has dropped, not risen. It's now similar to the rate in the UK, which has no assisted dying law.

ABC news standards

Since the ABC moved the Q&A program from its entertainment division to its news division there is a heighted obligation on the broadcaster to ensure that the show's content is reason- and evidence-based, and not merely a platform for anyone to promote silly misinformation in support of a perspective.

No doubt the ABC will rise suitably to the occasion of discouraging misinformation and ensuring that any is corrected.

We'll be watching the next episode of ABC Q&A closely to fact check anything Mr Shelton and others say about assisted dying law reform. Give us a bell if you spot anything you know or suspect is untrue.

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  1. Onwuteaka-Philipsen, BD, Brinkman-Stoppelenburg, A, Penning, C, de Jong-Krul, GJF, van Delden, JJM & van der Heide, A 2012, 'Trends in end-of-life practices before and after the enactment of the euthanasia law in the Netherlands from 1990 to 2010: a repeated cross-sectional survey', The Lancet, vol. 380, no. 9845, pp. 908-915.
  2. Seale, C 2009, 'End-of-life decisions in the UK involving medical practitioners', Palliative Medicine, vol. 23, no. 3, pp. 198-204.

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Neonatal deaths under Dutch Groningen Protocol very rare despite misinformation contagion


Author(s)

Neil Francis

Journal

Journal of Assisted Dying, vol. 1, no. 1, pp. 7–19.

Abstract

The Groningen Protocol specifies criteria for the potential termination of life in severely ill newborns in extremis with untreatable and unrelievable conditions. In September 2006 the Netherlands formally adopted a Regulation incorporating the Protocol. Despite the Regulation’s development through extensive professional consultation, endorsement by the Dutch Paediatric Association, empirical data showing a decrease rather than increase in use, and research showing that neonatal euthanasia occurs around the world in the absence of regulation, the Dutch Regulation has sparked controversy. More recently it has been claimed that hundreds of babies a year are killed under its provisions. Forensic analysis reveals the claim to be comprehensively and evidentially false. Wide online dissemination of the claim by mostly religious sources demonstrates confirmation bias and misinformation contagion.

Article keywords

Netherlands, Groningen Protocol, neonatal euthanasia, palliative sedation, neuromuscular blocker, non-treatment decision, confirmation bias, misinformation contagion, religion

Full PDF

Download the full PDF: Download the full article (230Kb)

Citation

Francis, N 2016, 'Neonatal deaths under Dutch Groningen Protocol very rare despite misinformation contagion', Journal of Assisted Dying, vol. 1, no. 1, pp. 7-19.

Download the citation in RIS format: RIS.gif


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It was inevitable, the latest attempt by senior British clergy to persuade politicians to reject Lord Joffe’s Assisted Dying for the Terminally Ill Bill. Led by the Archbishop of Canterbury, Justin Welby—whose predecessor Lord Carey now supports the reform—nine clergy sent a letter to ‘remind’ Parliament of supposed terrible consequences.

So what points did the clerics offer to Parliamentarians, and are they valid? Let’s take a look at each of the five ‘reasons’ advanced in order to deny Brits assisted dying choice.

Firstly, the clerics argue that the ‘answer’ is palliative care. Britain boasts the world’s gold standard in palliative care practice and it’s a great credit to practitioners. But the medical literature as well as the experience of the dying and their loved ones is conclusive: palliative care simply can’t always help. Experts say that “relief of suffering remains an elusive goal for many patients” and it’s “clear that improving palliative care will not remove the need for legalizing assisted dying.”

The premise of palliative care is to provide interventions. However, sometimes, not only does interventionism fail to help, it can itself be a source of suffering. And the individual may not want interventions, but rather to alight from the train of terminal illness one or two stops before the inevitable and intolerable terminus.

Secondly, the clerics argue that jurisdictions with assisted dying laws are facing serious problems, including wrongly claiming that the Dutch are now campaigning to include dementia as a basis to seek an assisted death. This right has been enshrined in Dutch law through advance care directives since 2002. In practice, the request is largely declined by doctors.

The clerics complain that dying patients in assisted dying jurisdictions are now using the law—hardly a surprising outcome given the proportion of people now dying of cancer in their later years.

They complain about supposed ‘doctor shopping’ in Oregon. If the patient’s first (or second) doctor declines a request to consider an assisted death on the basis of the doctor’s own convictions, are these clerics suggesting that the patient ought to have their right to lawful assessment denied, because their first doctor or two were religiously opposed?

Thirdly, the clerics argue that the majority of doctors are opposed to assisted dying law reform, ironically pointing out that a quarter to a third of doctors support reform. Why should Brits be denied a choice because two thirds of doctors currently won’t participate in that choice? (What proportion of doctors would participate in abortions, currently legal?) And doctors—who make up fewer than one in two hundred Brits—don’t elect Parliament, so why are their diverse views a case for outright denial?

Let’s name this argument for what it is: an appeal to apparent ‘authority’. Clerical ‘authorities’ (who don’t represent their flocks who are overwhelmingly in favour of reform) are making an appeal of medical ‘authorities’ as the reason to reject something the public believes should be a right. Paternalism indeed.

The fourth argument spreads an icing of hubris on the cake of objections. The clerics argue that the public really don’t understand and don’t know what they mean when the great majority keep saying ‘yes’ to repeated polls on assisted dying law reform.

Public opinion in fact demonstrates the opposite of gullibility: rejection of the attempted scare campaigns of religious ‘authorities’.

Fifthly (and thankfully lastly), the clerics argue that a right to choose assisted dying will inevitably become a duty to choose it. If the theory that ‘a right becomes a duty’ were an argument to reject one right, then all rights would necessarily be rejected on precisely the same principle.

Enshrined in the Mental Capacity Act 2005, Brits already have a right to refuse any medical treatment, even if life-saving. A Jehovah’s Witness may refuse a simple blood transfusion. An elderly person may refuse burdensome surgery. Yet the right to refuse treatment can theoretically become a duty to refuse, in exactly the same manner.

If the clerics genuinely believe their theory then they would argue to Parliament with equal force that the right to refuse medical treatment should be rescinded. Why don’t they?

The real reason for opposing the assisted dying Bill appears in the letter’s preamble: the clerics “hold all human life sacred”, in other words, a ‘gift from God’. Yet contemporary British Social Attitudes surveys reveal that the majority of Brits are not religious.

So the real question for the Parliament is this: should indefensible arguments put forward by a few clerical ‘authorities’ form a basis for denying choice wanted by the overwhelming majority of voters?


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The Council of Europe chamber in session.

On the 25th January 2012, the Council of Europe passed declaration 1859 on advance care planning. Immediately, lobbyists opposed to assisted dying loudly proclaimed that the resolution banned euthanasia across Europe, when it did nothing of the sort. What actually happened?

Declaration 1859 on advance care planning

The Strasbourg-based Council of Europe passed declaration 1859 on 25th January 2012. The declaration was about advance care planning, which allows patients to inform others about what treatments they would or wouldn't want if they become unable to participate in treatment decision-making.

The declaration made the explicit point that it was about advance care planning and not about euthanasia or assisted suicide.  It made the point that non-voluntary euthanasia is unacceptable—that is, that others should not make death-hastening decisions about a person for their 'alleged benefit'. This is an important point on which both sides of the assisted dying debate can agree.

Council of Europe resolutions are informative to members, but are not binding.

Misstatements by opponents of assisted dying

Despite this simplicity and clarity, the very next day after the vote, a host of conservative religious organisations and commentators began trumpeting that "the Council of Europe banned euthanasia across Europe." It started with the Catholic Church (through its online service Zenit) and sprinted right around the world in a matter of days—even appearing eventually in a professional journal paper two and a half years later.

What really happened: the evidence

But no matter how often and how loudly lobbyists try to claim that the Council of Europe banned euthanasia across europe, it did nothing of the sort.

Read the forensic analysis of the misinformation trail in the F files, here.


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The Council of Europe chamber in session.

Here’s a clear example of mistaken information (misinformation) — more commonly known as ‘bull’ — published by conservative opponents of assisted dying law reform. In this case, lobbyists and commentators misreport by fudge: by cherry-picking and repositioning a declaration of the Council of Europe, asserting that it ‘banned euthanasia' throughout Europe.

It did nothing of the sort.  So what actually happened?

The Council of Europe

The Strasbourg-based Council of Europe (not to be confused with the Brussels-based European Union or its strategic advisory body the European Council or representative body Council of the European Union) commissions careful studies into various subjects of importance to its member states.

In 2011, the Council’s  Social, Health and Family Affairs Committee conducted a study called “Protecting human rights and dignity by taking into account previously expressed wishes of patients.” Its purpose was to make recommendations about advance care directives, and enduring powers of attorney—also known in some jurisdictions as guardianship.  These are preferences, documented in advance by a person, which help ensure his or her healthcare wishes are respected and honoured at times when the person can’t currently decide and speak for him or herself. The Committee’s report was handed down as Document 12804.

Wednesday January 25th 2012

On January 25th 2012, declaration 1859 regarding the Committee’s report came before the Parliamentary Assembly of the Council of Europe (PACE) for consideration and a vote.

After most delegates had left the very lengthy session, some remaining delegates moved an amendment to the declaration. While it was procedurally their right to do so, they made the attempt only when some five sixths (268 of 318) of their Council colleagues were absent.  

David Pollock of the European Humanist Federation describes the delegates pushing the amendment as:

“an unlikely alliance of the Catholic Church and evangelicals like Pat Robertson who is behind the European Centre for Law and Justice.”

As a result, a statement mentioning euthanasia was added to the original declaration and was passed by (a tiny) vote.

You can read the entire declaration here.  It’s less than two pages.

Now, what the declaration has to say about ‘euthanasia’ appears exclusively in Clause 5, and Clause 5 says in its entirety:

“5.   This resolution is not intended to deal with the issues of euthanasia or assisted suicide. Euthanasia, in the sense of the intentional killing by act or omission of a dependent human being for his or her alleged benefit, must always be prohibited. This resolution thus limits itself to the question of advance directives, living wills and continuing powers of attorney.”

Notice that the clause contains exactly and only three short sentences.

  1. The first sentence is explicit and unambiguous: the declaration is not about euthanasia or assisted suicide.
  2. The second sentence makes it abundantly clear that hastened-dying decisions made by persons other than the patient themselves but alleged to be (i.e. by others) for a ‘dependent’ patient’s ‘benefit’ are unacceptable. Declaring against such non-voluntary euthanasia is a fundamental principle on which both sides of the assisted dying debate can agree. The resolution does not speak against voluntary euthanasia: that is, when a competent patient chooses assisted dying for themselves.
  3. The third sentence reiterates clearly that the declaration deals only with advance directives ('living wills') and continuing powers of attorney (persons granted the legal power to make decisions consistent with the advance directive). Note that the declaration wording does not even speak against assisted dying options within advance directives where permissible by law (e.g. as in the Netherlands), because these are made voluntarily by a competent patient on their own behalf and not by someone else for some 'alleged benefit’.

So, the declaration is not in conflict in any way with the laws of member states which already have assisted dying laws. Nor does it preclude other member states from introducing assisted dying laws.

Indeed, the declaration is not in conflict because the adoption of declarations by each member state is voluntary. It is incorrect to represent in any way that a Council of Europe declaration is a ‘determination,’ ‘ruling,’ ‘ban,’ ‘prohibition’ or other form of obligation upon its members.

But don’t just take my word for it.

Dr Stephen Latham, Director of the Interdisciplinary Centre for Bioethics at Yale University, states unequivocally in his blog on bioethics:

“… it’s a mistake to report it [the declaration] as a condemnation of assisted suicide, or to anticipate that it will have strong effect on pending cases involving assisted suicide.”

Dr Latham rightly points directly to the explicit declaration statement that it “is not intended to deal with the issues of euthanasia or assisted suicide." He further affirms that the European Court for Human Rights (a court of the Council of Europe) has held that Article 8 of the Convention for the Protection of Human Rights and Fundamental Freedoms protects the individual’s choice to avoid a painful and undignified death.

So, despite the clarity of the declaration, how long did it take for opponents of assisted dying to publish mistaken information about it?

Thursday January 26th 2012

Within mere hours of the vote, cherry-picked bull began charging around the globe.

Bolting energetically out of the paddock was the Catholic online newspaper promoting Vatican opinion, Zenit. Proclaiming jubilantly, “Anti-euthanasia ruling hailed as major victory”, Zenit stumbled at the first hurdle of truthfulness —the declaration was not, in any sense, a ‘ruling,’ nor called for a blanket “prohibition of euthanasia” as its lead paragraph states.[1]

Off to a similarly agile start was Dr Grégor Puppinck, Director General of the conservative Christian lobby group the European Center of Law & Justice — who you will remember David Pollock described above as in an alliance with the Catholic Church and others.  Published on the Catholic Family-backed Turtle Bay and Beyond blog, this article was wrongly titled “Major victory for life in Europe: euthanasia must always be prohibited.”[2]

For good measure, Dr Puppinck’s opinion piece, complete with alternate headline “Victory: Council of Europe adopts resolution against euthanasia”, was published the same day on the USA Christian/Catholic pro-life website LifeNews.com.[3]

Similarly, Christian/Catholic pro-life website LifeSiteNews.com's John Westen published a piece the same day titled "Major victory for life in Europe: ‘Euthanasia must always be prohibited'".[4]

Also on the same day, the conservative European think tank European Dignity Watch’s headline likewise cherry-picked words from the declaration: “Council of Europe bans euthanasia”.[5]

Wasting no time, the Swedish Christian “Yes To Life” group trumpeted the mistruth “Council of Europe prevents euthanasia in Europe!”  (The Council of Europe would be very talented indeed if it could actually “prevent euthanasia across Europe".)[6]

Canadian Alex Schadenberg’s Euthanasia Prevention Coalition also repeated the same cherry-picked nonsense with the headline “Council of Europe states that: ‘Euthanasia must always be prohibited.’”[7]

Friday January 27th 2012

Well-known UK Catholic journalist Simon Caldwell was only a shade slower out of the blocks just one day later.  His article’s headline in UK’s Daily Mail rates a comprehensive fail for saying “Euthanasia ‘must always be prohibited’, rules Council of Europe.”[8]

Saturday 28th January 2012

Another day later and the UK Telegraph republished the story, misstating “Assisted suicide should be illegal through Europe, human rights body rules.”[9] (While this article had no by-line, its copy was remarkably identical to Simon Caldwell’s pieces in the Daily Mail [above] and UK Catholic Herald [below]. Caldwell is a known writer for the Telegraph.)

Monday 30th January 2012

Simon Caldwell followed up with the same article in the UK Catholic Herald, again with a false headline “Euthanasia should be banned across Europe, rules Council.”[10]

Also on 30th January, Catholic-founded Australian Family Association's Paul Russel uncritically republished Alex Schadenberg’s opinion piece on their anti-voluntary euthanasia campaign site “HOPE”.[11]

Tuesday 31st January 2012

Not to be outdone, the next day the Patients Rights Council (formerly the International Task Force on Euthanasia and Assisted Suicide), an anti-euthanasia lobby group consisting essentially of two people (Rita Marker and Wesley Smith), uncritically summarised Simon Caldwell’s Daily Mail opinion piece.[12]

Wednesday February 1st 2012

On February 1st the polemic was republished in CathNews in Australia, with false headline “Council of Europe says ban euthanasia.”[13]

The Catholic Archdiocese of Sydney republished on its youth engagement website xt3, with the headline “Euthanasia should be banned across Europe, rules Council.”[14]

Friday February 3rd 2012

By February 3rd, the Church of England Newspaper had jumped on the bandwagon, misstating “Council of Europe assemby [sic] calls for ban on euthanasia.”[15]

So did the Scottish Catholic Observer with an extra dose of hyperbole: “European human rights body rules that euthanasia and assisted suicide should be banned in every country on the continent.”[16]

The misinformation was repeated on the Irish Catholic web portal CiNews, the blog site of conservative USA Christian organisations the Population Research Institute and The Moral Liberal, the Catholic parish for Wymouth Our Lady Star of the Sea, in an opinion piece by Catholic British Peer David Alton, the Perth Catholic Archdiocese LJ Goody Bioethics Centre, the Australian blog site of Catholic News Jesus Caritas Est, … I think you get the idea.

No wonder Yale University’s Dr Latham mused dryly in his blog:

“… a number of different publications are mistakenly alleging that PACE has called for a permanent ban on assisted suicide.”

September 19th 2012

Later in the year I was kindly invited to speak at a Brisbane public forum on the legalisation of voluntary euthanasia hosted by the Queensland Council for Civil Liberties. Mr Yuri Koszarycz, then recently retired lecturer in bioethics, ethics and church history from Australian Catholic University, spoke for the opposing position. Given the audience were paying to listen to our respective pearls of wisdom, it was paramount that our material be properly researched and backed by good evidence.

Yet Mr Koszarycz dropped the “R” bomb (amongst others) in his presentation: yes, he asserted that the Council of Europe had ‘ruled’ against euthanasia, when it clearly had not.

July 17th 2014

Dr Grégor Puppinck (remember, he’s Director General of the European Center of Law & Justice) makes another appearance, this time as the lead author of a paper published in the International Journal of Human Rights[17]. In it, he rails against his perception that when reviewing cases of assisted suicide, the European Court of Human Rights ‘ignores’ Council of Europe declaration 1859. To support his argument, he quotes the single sentence “Euthanasia, in the sense of the intentional killing by act or omission of a dependent human being for his or her alleged benefit, must always be prohibited” (p 746).

The paper’s discussion quite omits the two crucial, framing sentences, so a reader unfamiliar with the declaration’s original text would not know that it said it is “not intended to deal with the issues of  euthanasia or assisted suicide” and that it is about “living wills and continuing powers of attorney”. No wonder the European Court of Human Rights doesn’t believe that declaration 1859 is crucial when considering cases of assisted suicide: declaration 1859 is about advance care planning!

Indeed, a reader of the journal article could be forgiven for wrongly deducing, on the basis of the only sentence quoted by authors Puppinck and de la Hougue, that the Council had ‘banned euthanasia’.  It most certainly had not.

Conclusion

So let’s recap what happened. The primary facts are:

  1. The Council of Europe passed a declaration (#1859) about advance care planning—not about euthanasia or assisted suicide (it explicitly said it wasn't).
  2. The declaration spoke only against non-voluntary euthanasia (NVE)—not against voluntary euthanasia (VE) about which it contained no statement of any kind.
  3. Council declarations are in no way 'rulings', 'bans' or 'prohibitions' on its members because member adoption is entirely voluntary.

Yet despite the clarity of the declaration, quite a number of anti-euthanasia lobby groups and commentators, commencing the very next day and starting with the Catholic Church (through Zenit) and the European Centre for Law and Justice, published editorials mistakenly stating that the Council of Europe had ‘banned euthanasia': in other words, spreading bull.

A question that could be asked is this: how did it happen that so many anti-euthanasia individuals and groups published misstatements so closely together in both interpretation and in time?


[17]  Puppinck, G & de La Hougue, C 2014, 'The right to assisted suicide in the case law of the European Court of Human Rights', International Journal of Human Rights, vol. 18, no. 7-8, pp. 735-755.

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