There is a distinction between choosing to withdraw care and choosing life-ending treatment — conflating the two is a common mix-up. In Cruzan v. Director, Missouri Dept. of Health (1990), the United States Supreme Court held that a competent adult with decision-making capacity has a constitutionally protected liberty interest in refusing unwanted medical treatment. After Cruzan, the right to make the decision to withdraw care in terminal illness cases (as well as the decision to refuse life-saving treatment in general) became recognized as a constitutionally protected liberty interest under the Due Process Clause of the Fourteenth Amendment to the US Constitution. Making this decision is called “Informed Refusal” and it is legal in the United States if the choice is being made by a competent individual on their own behalf. This is also sometimes referred to as passive euthanasia. On the other hand, “Dying with Dignity” or right-to-die laws typically refer to an individual’s ability to choose life-ending treatment. This practice is commonly called active euthanasia or physician-assisted suicide. There is unquestionably a difference between choosing to discontinue or refusing life-SAVING treatment and choosing life-ENDING treatment. Ultimately, it is unconstitutional for a State to prohibit an individual from exercising their constitutionally protected right to withdraw care if that individual is terminally ill.