The case primary issue surround the Theresia Schiavo was well articulated by Wolfson (Wolfson, 2006). Ms. Schiavo did not have a healthcare decision surrogate and did not have a living will that articulated he wishes surrounding end of life care. In other cases, where substitutes decision making is sound if based on the known desires of the patient (Pozgar, 2016, p. 416). In other cases, courts, have refused to stop medical treatment because the wish of the incompetent patient is un clear (Pozgar, 2016, p. 417). The rights of the patient to allow or refuse treatment are paramount in end of life decisions. The best possible option to provide a clear and convincing evidence for Ms. Schiavo’s wishes would have been an executed living will. A
