1. See People v. Kevorkian, 210 Mich. App. 601, 534 N.W.2d 172 (1995).
2. See id. at 604–605.
3. See Pamela Warrick, Suicide's Partner, L.A. Times, Dec. 6, 1992, part E, at 1, col. 2.
4. See Isabel Wilkerson, Prosecutors Seek to Ban Doctor's Suicide Device, N.Y. Times, Jan. 5, 1991, sec. 1, at 6, col. 5.
5. See Brian Murphy, Kevorkian, Silent, Starts Prison Term, Detroit Free Press, Apr. 14, 1999, available at http://www.freep.com/ news/extra2/qkevo14.htm (hereinafter Murphy, Kevorkian Silent).
6. In 2004, the Hemlock Society changed its name to “End of Life Choices.” It then merged with Compassion in Dying (CID) to form what is now known as Compassion and Choice. See Wesley J. Smith, Weekly Standard, available at http://www.theweekly standard.com/content/public/articles/000/000/0004/471lzceh.asp (Aug. 16, 2004). CID was itself originally spun off of the Hemlock Society to focus on assisting suicides, as distinct from the Hemlock Society's legal and political advocacy work. See id.
7. Derek Humphry, Law Reform, 20 Ohio N.U. L. Rev. 729, 731 (1994).
8. See Charlie Cain (comp.), Key Events in the History of Michigan's Debate over Abor tion and Assisted Suicide, The Detroit News, Mar. 2, 1997, at A8.
9. As developed by Dutch courts, the emergency defense applied when (a) a patient requested assistance freely and voluntarily; (b) the request was well considered, durable, and persistent; (c) the patient was experiencing intolerable suffering with no prospect of improvement; (d) other alternatives to alleviate the patient's suffering had been considered and found wanting; (e) any act of euthanasia was performed (only) by a physician; and (f) the physician had consulted an independent colleague. See Report of the Select Committee on Medical Ethics, House of Lords, HL Paper, 21-I, 1993–1994 (hereinafter House of Lords Report HL Paper 21-I of 1993–1994 Session), appendix 3, infra. These criteria paralleled professional guidelines established by the Royal Dutch Medical Association. See Walter Lagerway (trans.), Guidelines for Euthanasia, 3 issues, L. & Med. 429 (1988).
10. See Netherlands Parliament Legalizes Euthanasia, available at http://www. euthanasia.com/netherlands2000.html; CNN.com/WORLD, Dutch Law Stokes Death Debate, available at http://archives.cnn.com/2001/WORLD/europe/04/11/euthanasia. debate.index.html (site visited Oct. 5, 2005). See also ch. 7.1, infra (discussing legislative changes).
11. For a thorough account of how the Australian law came about, its procedures, and