EAS is legal in the Netherlands when, according to Bolt’s paper, there is “the presence of unbearable suffering without the prospect of improvement” and “a voluntary and well-considered request”; “the patient is informed about the situation and prognosis”; there is “the absence of reasonable treatment alternatives”; there has been “consultation with a second physician”; and “EAS is performed with due medical care and attention.” Physicians can administer lethal drugs or provide them, and people as young as 12 can request EAS. After the physician performs the act, a review committee determines whether the death met the required conditions.

Belgium, Luxembourg and Switzerland also permit physician-assisted suicide, the term that Bolt uses in the paper—some advocacy groups in the United States prefer “aid in dying,” while groups opposed to the practice use the phrase “assisted suicide.” Last week, the Supreme Court of Canada overturned a ban on euthanasia; the parliament there now has one year to write up a law. And in the U.S., assisted dying is legal in five states for patients who are mentally competent and have six months or less to live and can self-administer the life-ending medication. People with dementia are ineligible.

“The European model is very different from the U.S. model,” says Sean Crowley, a spokesman for the “end of life” U.S. advocacy group Compassion and Choices.