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===Extraordinary means=== [[Catholic moral theology]] does not require that "extraordinary means" be employed to preserve a patient's life. Such means are any procedure which might place an undue burden on the patient, family, or others and which would not result in reasonable hope of benefiting the patient. It is considered ethical for a person (or a person's representative in cases where the individual is not able to decide for themselves) to refuse extraordinary means of treatment even if doing so will hasten natural death.<ref>{{cite journal|last=McCartney|first=James|title=The Development of the Doctrine of Ordinary and Extraordinary Means of Preserving Life in Catholic Moral Theology before the Karen Quinlan Case|journal=Linacre Quarterly|date=1980|volume=47 |issue=215}}</ref><ref>{{cite journal|journal=Health Progress|date=March 1985|title=Catholic theology and the right to die|last=Coleman|first=Gerald|volume=66|issue=2|pages=28β32|pmid=10270328}}</ref> It is to this Catholic principle that Quinlan's parents appealed when they requested that the extraordinary means of a ventilator be removed, citing a declaration by [[Pope Pius XII]] from 1957.<ref name="Stryker"/><ref>{{cite book|last=Scheb|first=John|title=Criminal law|date=March 28, 2011|publisher=Wadsworth Publishing|isbn=978-1111346959|page=85}}</ref>
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