The lack of relief and the unwanted treatment occur even though laws, courts and hospitals support carrying out such requests, the study noted.

The constitutional connection between the right to have an abortion and the right to halt unwanted medical treatment may not be obvious on the surface.

A patient has the right to contest in court any forced hospitalization, transfer to a state hospital or unwanted medical treatment.

The liberty interest discussed in Cruzan was necessarily limited to the refusal of unwanted medical treatment.

The states have drawn a line between an individual's right to refuse unwanted medical treatment and intentionally killing oneself, with or without assistance.

On the contrary, she said, doctors have been sued for refusing to stop unwanted treatment.

The Court of Appeals had not ruled before on whether a patient is financially liable for unwanted life-sustaining treatment.

Such a decision, Justice Brennan said, "robs a patient of the very qualities protected by the right to avoid unwanted medical treatment."

In a number of court cases, patients or their representatives have won the right to stop unwanted treatment.

We have also assumed, and strongly suggested, that the due process clause protects the traditional right to refuse unwanted lifesaving medical treatment.