November 30-December 1, 2007, over three hundred people from various nations met in Toronto, Ontario for a history-making event, The First International Symposium on Euthanasia and Assisted Suicide: Current Issues, Future Directions. Hosted by the Euthanasia Prevention Coalition of Canada (EPCC), the symposium was co-sponsored by diverse groups from Canada, the United States and the United Kingdom as well as the Archdiocese of Toronto. With one thing in common—opposition to legalization of euthanasia and assisted suicide—disability rights advocates, medical and legal professionals, pro-life activists, people of various religious faiths and atheists came together to learn from the experts, find common ground and strategize

Presenters exposed the new directions and strategies of the movement to legalize euthanasia and assisted suicide. According to Wesley Smith, who is a senior fellow at the Discovery Institute, attorney, international lecturer and author of several books on bioethics (just to name a few of his credentials), “The euthanasia movement has become much more sophisticated in the last few years.” The “crackpot element” is no longer driving the movement. It is now “a professional model” and “an elitist establishment movement” whose pitch is “just a little extra choice for people who are dying.”

The thread running through all the presentations was the urgent need to establish a common response to this world-wide threat. Many of the speakers were key participants in coalitions that defeated pro-euthanasia and assisted suicide legislation in the US and UK. They outlined the lessons they’ve learned.

Use the Right Language
One lesson learned is that “all social engineering is preceded by verbal engineering,” stated Rita Marker, attorney and executive director of the International Task Force on Euthanasia and Assisted Suicide. “The words used in a debate often determine the outcome of the debate.” Assisted suicide activists blame their failures on the use of the word “suicide” and insist on using what they call “value-neutral” terms. Marker advised symposium participants to always use the term “assisted suicide,” never terms such as “assisted dying” or “aid-in-dying.” The “s” word is powerful.

Dr. Peter Saunders, of Care Not Killing Alliance in the UK, helped defeat the “Joffe” bill, an assisted suicide measure. As an example of effective use of language, he cited a disabled person’s sound bite: “We don’t want assisted dying. We want assisted living!”

Dr. Paul Byrne, a neonatologist and Clinical Professor of Pediatrics at Medical University of Ohio, insisted that the term “euthanasia,” which literally means “good death,” should not be used. The term “imposed death,” he said, is more accurate

Emphasize Bad Consequences
Dr. Saunders, as well as the disability rights advocates who spoke, pointed out that changing the law will put pressure on vulnerable people to choose death rather than be “a burden” on others. Also, euthanasia and physician-assisted suicide (PAS) will be used to contain healthcare costs. Oregon pays for PAS as “comfort care” while refusing to pay for certain types of medical care for cancer patients.

In 2007, Dr. Robert Orr helped defeat a bill that would have legalized PAS in Vermont for persons with a life-expectancy of less than six months. “Inaccuracy of diagnosis,” he said, should be emphasized. He cited Art Buchwald, who was suffering from kidney failure and refused dialysis. He entered hospice in February 2006 expecting to die, but checked himself out several months later. Buchwald lived for nearly a year and wrote a book entitled “Too Soon to Say Goodbye.”

Dr. Orr outlined how, once legalized, euthanasia in the Netherlands slowly expanded from being permitted for patients who are competent and suffering to being imposed on “patients with no free will” and even infants with disabilities. The slippery slope is real.

Cheryl Eckstein, founder of Compassionate Healthcare Network (Canada) gave a rundown of Canadian “mercy-killing” cases. She said that the notion of “‘compassionate homicide’ is about as nonsensical as ‘loving rape.’” And Dr. Bill Toffler, national director of Physicians for Compassionate Care, lamented that his beautiful state of Oregon has “sadly become known for something that is deeply disordered.”

Personal Stories
As one participant said, “The shortest distance between a person and the truth is a story.”

Soft-spoken Alison Davis, representing No Less Human, a disability rights group in England, told her story. Because of her disability, she has constant pain and is dependent on morphine for relief. She told of times when she had wanted to die due to suffering and depression. If the UK had allowed assisted suicide, she expressed doubt that she would be here today. Davis emphasized the danger of legalizing euthanasia and assisted suicide: “Pain control is available, but it takes time and effort. Why bother if killing the patient is equally acceptable?”

Henk Reitsema, an articulate young man from the Netherlands representing Cry for Life, told the compelling story of his grandfather’s death by involuntary euthanasia in a Dutch nursing home. He said, “The way my grandfather died might be described as ‘palliation with the side effect of death,’” which is a common way of imposed death in his country. We “seem to have made the suffering of pain the only crime worth punishing with the death penalty,” declared Reitsema.

The familiar story of Terri Schindler-Schiavo’s dehydration death in a Florida hospice was related by her brother Bobby Schindler. There was not a dry eye in the room as he described Terri’s last days and the suffering her family endured and continues to endure because of her cruel death.

Dr. Paul Byrne’s topic was “brain death.” He told of several cases that compelled him to begin evaluating whether “brain death” is true death, or not. The first was in 1975. Joseph, a premature infant, had been on a ventilator for six weeks and an EEG was interpreted as “consistent with cerebral death.” Dr. Byrne did not turn off the ventilator; rather, he continued treatment. Joseph is now married with children and works as a fireman and paramedic.

Get Involved

Euthanasia and physician-assisted suicide are now “medical treatment” in the Netherlands and Belgium. Switzerland does not penalize assisted suicide so long as it is not done for selfish motives, but physicians cannot be involved. In the U.S., PAS is legal only in Oregon. Opposition coalitions have defeated 89 efforts to legalize it in other states.

Compassion & Choices, the U.S. organization leading efforts to legalize PAS, has adopted the slogan “Oregon Plus One.” PAS promoters are determined to legalize assisted suicide in at least one more state in 2008. They are targeting Washington State in particular. Booth Gardner, popular former governor of Washington who now has Parkinson’s disease, is putting his popularity and considerable fortune behind the campaign to gather the 225,000 signatures needed by July to place a PAS initiative on next November’s ballot.

Rita Marker warned, “Any place that assisted suicide passes will affect the whole world.” Everyone who opposes assisted suicide, she said, “is a Washingtonian for the next year. You are important. Get involved.”

Conclusion
The sponsors and organizers, in particular Alex Schadenberg, executive director of the EPCC, deserve hearty congratulations for the shining success of this first of its kind symposium.

As a patient advocate and a speaker on medical decision-making, the questions I am most frequently asked concern the withdrawal of food and fluids from persons who are seriously ill or persistently non-responsive (often referred to as being in a persistent vegetative state). If my audience is Catholic, I quote Catholic sources, such as the Catechism of the Catholic Church (CCC) and statements made by Popes and Bishops. If not, my answer is basically the same without naming the source of my wisdom. I get a kick out of non-Catholics who respond enthusiastically. For instance, after I spoke to a Lutherans for Life group, one woman asked, “How did you gain the knowledge and ability to address this confusing issue so clearly?” With a chuckle I confessed to “plagiarizing” the teachings of the Catholic Church.

The Catholic Church, more than any other entity, unambiguously proclaims the truth, very clearly drawing the line between good and evil, right and wrong. Medical decision-making, in particular, calls for such sound moral guidance.

The Church defines euthanasia as “an act or omission which, of itself or by intention, causes death in order to eliminate suffering” and calls it a “murderous act” [CCC, 2277]. Very simply then, if the withdrawal of food and fluids will be or is intended to be the cause of a person’s death, it is a morally unacceptable murderous act. In 1992, the Committee for Pro-Life Activities of the National Council of Catholic Bishops warned:

…nutrition and hydration (whether orally administered or medically assisted) are sometimes withdrawn not because a patient is dying, but precisely because a patient is not dying (or not dying quickly enough) and someone believes it would be better if he or she did, generally because the patient is perceived as having an unacceptably low “quality of life” or as imposing burdens on others.

Promoters of euthanasia call it “death with dignity,” a term that often masks a disdain for those who are weakest and most in need of human kindness. The professional obligation of physicians and nurses is to care for and preserve life where they can, not to preside over the planned deaths of patients whom they or others deem “better off dead”. Nevertheless, widespread legal and medical endorsement for ending lives by dehydration and starvation has misled many people.

On March 20, 2004, Pope John Paul II, for those who would listen, definitively put an end to any confusion about what the Church teaches on this matter. Addressing the International Congress on “Life-Sustaining Treatments and Vegetative State”, the pope said, “I should like particularly to underline how the administration of water and food, even when provided by artificial means, always represents a natural means of preserving life, not a medical act.” He called their administration “morally obligatory”. Like any seriously ill person, a person in a “vegetative state”, he said, “has the right to basic health care (nutrition, hydration, cleanliness, warmth, etc.).”

In 2005, when the fate of Terri Schiavo was being decided by a Florida court, Archbishop Raymond Burke spoke in defense of her life:

If Mrs. Schiavo were facing imminent death, or were unable to receive food and water without harm, then removing nutrition and hydration would be morally permissible. It is however never permissible to remove food and water to cause death. Food and water are basic human needs, and therefore basic human rights.

Archbishop Burke’s statement is a basic guide for making moral decisions regarding nutrition and hydration. It is also prudent to remember the Pope’s words that provision of food and water, even by artificial means, is not a medical act. Food and fluids do not become “treatment” when they are taken by tube anymore than penicillin or Pepto-Bismol becomes “food” when taken by mouth.

Physician-assisted suicide (PAS) was legalized in Oregon in 1994. That law permits a doctor to prescribe a lethal dose of drugs at the request of a patient who is expected to die within six months. Thus far, every other state has resisted similar legislation thanks to the efforts of organizations and individuals opposed to PAS, including the Catholic Church. While the very public push to legalize assisted suicide diverted our attention, some ethicists and doctors quietly proposed a legal, but just as lethal, alternative – terminal sedation – and incorporated it into the practice of palliative medicine.

The word “palliative” describes care that comforts and relieves or moderates pain and suffering, such as the care provided by a hospice. “Terminal sedation” is a term recently added to the stock of medical phrases most people do not understand. But it is vitally important that people do understand this controversial, increasingly common method of permanently ending a person’s suffering.

“Terminal sedation” (TS) essentially means that a patient is given a sufficient amount of drugs to render and keep him unconscious until he dies, usually days or weeks later. No further active treatment is done and nutrition and hydration are often withheld. TS is also referred to as “palliative sedation” or “total sedation”. The National Hospice and Palliative Care Organization (NHPCO) presses hospice agencies to adopt TS and make it “a comfortable addition to the palliative care repertoire” (Goldstein-Shirley and Fine, “Ethics of Total Sedation”, NHPCO Ethics Committee). The claim is made that TS is aimed at relieving pain and suffering, not the intentional death of the patient. That claim is misleading. One might wonder if it is an intentional half-truth, but it is impossible to know another’s intention. Facts, on the other hand, can be examined to discern whether or not TS is, in any given case, mercy or murder.

Sedation is an important medical intervention for some patients who are near the end of life and have symptoms—pain, difficulty breathing, agitation, etc.—that have become progressively more difficult to manage and when nothing else will work. Sedation should only be used to relieve severe physical distress and never to intentionally shorten life. When used for medically and morally appropriate reasons, sedation is merciful.

However, TS is not limited to patients who are so near death that further treatment and/or food and fluids will no longer sustain their lives. Sometimes TS and withdrawal of nutrition and hydration are combined to introduce a cause of death—dehydration—unrelated to the patient’s illness. Sedation is used to keep the patient unaware as dehydration ravages his/her body. Death by sedation and dehydration can take up to two weeks or longer. For this reason, TS is sometimes called “slow euthanasia”. The Catechism of the Catholic Church defines “euthanasia” as “an act or omission which, of itself or by intention, causes death in order to eliminate suffering” and calls it a “murderous act”.

Sedation combined with dehydration is the treatment of choice for some patients who are not dying quickly enough to suit themselves or others. Regardless of who makes the decision, it is wrong. And, even though it may be legal, it is evil to deny food and water to anyone unless they will make the person’s condition worse or will no longer sustain life.

Regrettably, medical ethics and practice have largely degenerated from concern for doing what is right to merely doing what is legal. Obviously, what is legal is not always right.

(Originally published December 2006)

Hailed as a groundbreaking pioneer by the “right to die” movement and treated as a celebrity/hero by the media, Jack Kevorkian literally got away with murder. This unemployed pathologist was popularly known as “Dr. Death”. By his own count he assisted the “voluntary” deaths of more than 130 people in the 1990s, using either intravenous drugs or carbon monoxide gas. Yet, he was convicted of only one murder.

Kevorkian chose Michigan as his killing field because, until 1998, it had no law banning assisted suicide. Assisted suicide means that assistance is given by another to a person who performs the last act that causes his or her death. For example, it is assisted suicide when a person self-administers drugs prescribed by a doctor for the purpose of causing death (as is legal in Oregon).

In 1998, Kevorkian videotaped himself giving a lethal injection to Thomas Youk, who had Lou Gehrig's disease, in what was clearly a homicide, not an assisted suicide. Kevorkian then submitted the video to CBS which broadcast it nationally on “60 Minutes”. It was also presented as evidence in court. The prosecutor said, “He came like a medical hit man in the middle of the night with a bag of poison to do his job.” Serving as his own attorney, Kevorkian retorted, “I call it a medical service.” A jury found him guilty of second-degree murder.

Kevorkian preyed mainly on struggling disabled persons who were not terminally ill. Disability rights activists were understandably outraged when the Michigan Parole Board announced in December that he will be paroled next summer after serving only a little over eight years of a 10-25 year prison sentence.

In a news release, Sister Monica Kostielney, president and CEO of the Michigan Catholic Conference, objected to the early release of “an individual who perpetrated the crime of murder over 130 times.” “Assisted suicide,” she stated, “represents an affront to the dignity of the human person, a crime against life and an attack on humanity.”

Kevorkian began his killing spree on June 4, 1990 when he used a homemade “self execution machine” to kill Janet Adkins of Portland, Oregon. The contraption was a series of three bottles suspended from a pole and attached to an intravenous line. The first bottle contained saline solution, the second an anesthetic, and the third a lethal concentration of potassium chloride to cause cardiac arrest. Once Kevorkian started the intravenous saline solution, Mrs. Adkins is said to have pushed a button to deliver the contents of the other bottles into her bloodstream. Kevorkian had not met or talked to Mrs. Adkins until the night before he assisted her suicide in his rusty Volkswagen van at a campground north of Detroit. Although Mrs. Adkins reportedly had Alzheimer’s disease, she played tennis with her son the week before she was killed—and won.

Within hours of Mrs. Adkins “exit” from this life, Kevorkian and his suicide machine were front page news across America. On one news broadcast Kevorkian proclaimed, “It is time for death control.” In the ensuing months and years, Kevorkian proved that he meant it by leaving a trail of dead bodies in Michigan.

Kevorkian’s attorney, Mayer Morganroth, says his client will not kill again. The parole board considered the 78-year-old Kevorkian’s declining health along with the question of whether he would be a danger to society if set free. “They decided he is safe for release,” according to Corrections Department spokesman Russ Marlan. Once the nation’s most well-known advocate for assisted suicide, Kevorkian recently told the Los Angeles Times, “I have not changed my views on assisted suicide, but I believe it should be performed legally, and I would do whatever my health permits regarding petitions, speeches, lobbying and writing in support of legalization.”

Regardless of the parole board’s judgment, “Dr. Death” is a genuine danger to society. This unrepentant serial killer will be let loose to spread his poisonous ideas—and ideas have consequences. Furthermore, paroling him will send as strong a message as the fact that he got away with at least 129 murders before being convicted of one. The message is that killing vulnerable human beings is not a very serious crime against humanity, that it may even be excusable. With Jack Kevorkian’s release from prison, one more barrier against killing will come tumbling down.

A euphemism is language that softens or masks an unpleasant truth. In City of God, St. Augustine wrote, “God’s command, ‘Thou shalt not kill,’ is to be taken as forbidding self-destruction — anyone who kills a human being, himself or another, is guilty of murder.” That is a plain, hard truth. Promoters of euthanasia and assisted suicide call killing a human being who is sick or disabled “death with dignity.” That is a euphemism.

Oregon’s Death With Dignity Act, the only law of its kind in the nation, permits a physician to prescribe a fatal drug dose upon the request of a person who is expected to die within six months. Willfully taking a mouthful of pills in order to end one’s life is suicide, but “right to die” activists dislike such honest and direct language. Their polling data revealed that when a softer term such as “physician-aid-in-dying” was used instead of “physician-assisted suicide” to describe exactly the same proposal, the proposal garnered significantly more support. So, they demanded a change in language, believing that not calling suicide what it is would help legalize physician-assisted suicide (PAS) in other states.

In 2006, each and every assisted-suicide measure failed even though PAS activists thought they were going to taste victory in many states. They blamed their failures on the media for using the word “suicide” to describe these measures. But the death marketers never give up, they just craft a new advertising campaign. Already in 2007, several states have PAS proposals before their legislatures—Vermont, for instance. Dr. David Babbott, who supports that state’s “Death With Dignity” bill, declared, “We believe that ‘S’ word is an inflammatory word and we don’t use it.” (Darren Perron, Channel 3 News, Montpelier, VT, 1/12/07)

Compassion & Choices—a group formed by the merger of End of Life Choices (formerly the Hemlock Society) and Compassion In Dying—has helped facilitate the deaths of about three-quarters of the Oregonians who have requested PAS. George Eighmey, director of Compassion & Choices of Oregon, claims they often hear from people who want to avail themselves of the law, but who find the term “physician-assisted suicide” offensive. (The Oregonian, 11/11/06) Obviously, the social stigma and religious prohibitions attached to the act of killing oneself make the word “suicide” a powerful deterrent. And, just as obviously, Eighmey and his colleagues don’t want anyone to be deterred from committing suicide under the law. Therefore, last year, his group lobbied Oregon’s Department of Human Services (DHS) to adopt “value-neutral language.” Not wanting a court battle, the agency capitulated. DHS now blandly refers to patients who ask physicians to help them commit suicide as "persons who use the Oregon Death With Dignity Act."

Following suit, the American Public Health Association (APHA), which represents more than 50,000 members, has rejected the term “assisted suicide” in favor of “aid-in-dying” or “patient-directed dying.” APHA’s Governing Council adopted an interim resolution in November that advises reporters, educators, public policy makers and medical personnel to use these “value-neutral terms.” Compassion & Choices is banking on many of us being gullible enough to believe that suicide isn’t really suicide when medical professionals say it isn’t.

The plan of action of “right to die” activists is and always has been to work on society in order to bring about new attitudes favorable to euthanasia and assisted suicide. Do not be seduced by the death marketers’ spin. Even the high-sounding title of their “Death With Dignity” measures is a lie. Where is the dignity in self-destruction? Where is the honor in helping another commit suicide?

If it takes false advertising to sell a law, you can bet your life there’s something wrong with it.

Visiting the sick is a Christian work of mercy. Mercy is similar to compassion, which means “to suffer with” another, but it is more challenging than mere compassion. Mercy is putting our kindly inclinations—which we are often tempted to resist—into practice through readiness to assist.

A relative or volunteer advocate who accompanies a medically vulnerable person to doctor appointments or stays with the person when hospitalized contributes immeasurably to his or her well-being. The term “patient advocate,” as used here, means a person who strives to safeguard the welfare of a patient in the health care system. Particularly in need of patient advocates are persons whose lives are devalued—the mentally impaired, physically disabled, chronically ill, incurable, elderly and/or poor. In light of society’s growing willingness to abbreviate the lives of unwanted persons (both pre-born and born) patient advocates truly may be the last line of defense for some patients’ lives.

One essential role of the patient advocate is to facilitate communication between patient and physician. Before a visit with a doctor (in office or hospital), the advocate compiles a list of the patient’s symptoms, concerns and questions. During the visit, the advocate makes certain that all of these matters are satisfactorily addressed. The advocate also takes notes or tapes the conversation so the doctor’s advice can be reviewed later with the patient. This will help prevent misunderstandings and hopefully ensure compliance when the doctor prescribes medications or treatments.

Some hospitalized patients become disoriented in unfamiliar surroundings. They may feel acutely cut off from others and betrayed by their own bodies. A familiar face helps orient the patient and prevents loneliness, isolation, fear and despair. Rest is essential to recovery, but often difficult to get in a hospital. A patient may need someone he trusts by the bedside in order to feel secure enough to go to sleep. An advocate can minimize noise, light and other distractions by closing the door while with the patient. Particularly vulnerable patients need a caring person with them 24/7. Recruiting and scheduling family members, friends and volunteers to fill all the hours is another important role of the patient advocate.

Many hospitals are short-staffed and every hospital has times when the staff is extremely busy. (This also applies to nursing homes.) These problems can translate into less attentive care and even life-threatening situations. Busy medical personnel may overuse tranquilizers and physical restraints for patients who are restless or demanding. Feeding tubes are sometimes used for patients who are able to swallow simply because the staff does not have time to spoon-feed them. Call bells may be ignored when help is urgently needed. The advocate is able to soothe the restless patient, prevent him from pulling out tubes or falling out of bed, assist with meals, offer drinks of water, go for help in an emergency, etc. Whatever the advocate does to improve the patient’s welfare also positively influences others’ attitudes toward the patient. Some medical personnel perceive certain patients as being of “low value” and therefore give them less care or even think they would be “better off dead.” The advocate’s watchful presence is apt to induce such staff members to be more attentive to the patient’s needs.

Possibly the most important role the patient advocate plays is being a visible ally of the patient—a sign to the world that this patient is valued and that caring for and protecting this patient is a commendable moral act. A work of mercy, indeed.

If you would like to become a patient advocate or want more information on this subject, I recommend reading: A Guideline on Protecting the Health and Lives of Patients in Hospitals, Especially if the Patient is a Member of a Societally Devalued Class (106 pages), Second Edition (2005), by Wolf Wolfensberger. Available from Syracuse University Training Institute, 800 South Wilbur Avenue, Suite 3B1, Syracuse, New York 13204; telephone 1-315-473-2978.

Imagine visiting your 75-year-old mother in the hospital after she has had a disabling stroke. She is unable to speak or swallow. Her immediate needs include artificially provided food and fluids (tube-feeding) and antibiotics to fight an infection. If she survives, nursing home care as well as physical and speech therapy will be required to help her recover. Your mother chose you to be her health care decision-maker (agent) and told you that, no matter what, she wants to live. Nevertheless, her attending physician refuses to provide further “life-sustaining treatment”—including tube-feeding. When you object, the doctor explains that this is what he thinks is best for your mother. You are stunned.

Sound far-fetched? It’s not. Similar scenes are playing out all over the country in hospitals which have quietly adopted “futile care policies.” These policies are based on the theory that a physician is entitled to refuse life-sustaining treatment when he/she believes the quality of a patient’s life is too low or the cost is too high to justify further treatment. Such policies permit so-called “futile care” to be stopped, not because the care or treatment won’t sustain the patient’s life, but precisely because it will. If the patient, family or agent objects, the case is referred to the hospital ethics committee for the final decision.

A hard question needs to be asked. Is it advisable, or even legal, for doctors and hospital ethics committees to have this kind of power?

In 1998, I was interviewed for an article entitled “Medical Futility: Who has the power to decide?” which appeared in Nurse Week and Health Week. I said then that I believe medical futility policies are designed for one reason: cost-containment. And, I say it again. The high-sounding motive of “doing what is best for the patient” is simply camouflage.

Most people assume that they will have the right to make their own medical decisions. Insistence, against a patient’s wishes, that every means be used to postpone death would be senseless and inhumane. (While we have a moral obligation to use ordinary means to preserve our lives, treatments that are extremely burdensome, overly zealous or otherwise extraordinary are optional.) However, it is just as cruel to refuse available and potentially effective treatment to a patient who wants it. If a person wants to fight for every last moment of life, this is his or her right. There is absolutely no concern for the rights of patients in “futile care” policies.

Not only do these policies permit the wishes of a patient’s family and even a patient’s advance directive (Living Will or Power of Attorney for Health Care) to be ignored, they also allow doctors to override the medical decisions of a patient who is conscious and asserting the desire to live! The essence of any “futile care” policy is involuntary euthanasia by omission. [Catechism of the Catholic Church (CCC), 2277-2278]

“Futile care” policies make people with disabilities extremely nervous. Diane Coleman, president of the disability rights group Not Dead Yet, says, “It’s not news to us that health professionals judge our quality of life to be far less than how we judge it ourselves. The view that our lives are futile is frightening, no matter who holds it.” (“A Duty to Die” by Karla Dial, Citizen magazine, 2/04.)

“Quality of life” judgments are extremely unsettling. Based on the notion that certain lives are not worth living, they are totally incompatible with the fundamental Christian principle that “human life is sacred.” [CCC, 2258] Part of the spiritual war being waged between the Culture of Life and the Culture of Death is the ethical battle between the Sanctity of Life Ethic and the Quality of Life Ethic. We all have a stake in the outcome. If the Quality of Life Ethic prevails, hospitals may as well post signs warning patients, “We reserve the right to refuse treatment to anyone.”