Although Friedrich Nietzsche was not noted for his views on medical ethics, the above quotation captures the essence of James Lindgren\u27s article. Lindgren posits that the recent O\u27Connor\u27 and Cruzan decisions signal a shift in the law on the withdrawal or withholding of treatment. He concludes that the requirement set forth in those cases-that an individual must have clearly and convincingly expressed his or her wishes before treatment can be terminated--errs unduly on the side of life. Basing his conclusion primarily on preferences revealed by public opinion polls, he contends that a better rule would be to presume, subject to proof otherwise, that an individual desires death when the individual falls into one or more of fourteen specified categories