The claimed interests of the State in this case are essentially the preservation and sanctity of human life and defense of the right of the physician to administer medical treatment. There may be as many as thirty-five thousand Americans diagnosed as being in a vegetative state (VS), and nearly 30 percent of them are children. This 'disorder of consciousness', which also goes by the name unresponsive wakefulness syndrome results from severe brain damage that leaves the person without any awareness of self, although reflexive behavior and sleep-wake cycles are preserved. The critical difference between physician-assisted death (PAD) and VS patients is that by legal definition in the states that permit assisted death the person is conscious and capable of making an autonomous decision, to exercise the right of self-determination. Three women, united by the tragic circumstances of their deaths, are icons of contentious dying in the public mind: Karen Ann Quinlan, Nancy Cruzan, and Theresa Marie Schiavo.