Drawing on the model of estate wills, an Illinois lawyer named Luis Kutner1 proposed the living will in a 1969 article. In the aftermath of the Karen Ann Quinlan case,2 California became the first state to statutorily recognize the living will as an advance care document. In 1980, California also became the first state to enact legislation to legally recognize health care proxies who could terminate life-sustaining medical treatments. Through Supreme Court rulings and statutes, Americans have the constitutional right to express their wishes for terminating medical treatments, and living wills and other types of advance directives (ADs) are legally recognized mechanisms for expressing these and related preferences.
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