The “right to die” litigation that dominated American healthcare jurisprudence in the last three decades of the twentieth century, culminating in the Supreme Court decisions in Cruzan, Glucksberg, and Quill, confirmed the almost unqualified right of competent patients to refuse any and all medical interventions, for any reason or no reason, even when those interventions may be absolutely essential to preserve life. Although the courts acknowledged certain “countervailing” interests of the states that must be taken into account when patients directly, or indirectly through designated surrogates, refuse “medically indicated” treatment, only rarely have those interests been deemed of sufficient weight to override the clearly articulated wishes of patients.