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From: Theological History of Catholic Teaching on Prolonging Life, Gary M. Atkinson, Ph.D, Chapter 7 of Moral Responsibility in Prolonging Life Decisions ed. by McCarthy & Moraczewski
(Pope John Center, St. Louis, 1981, distr. by Franciscan Herald Press Chicago);

DANIEN A. CRONIN
(1927- )

The most complete work on the history of the ordinary/extraordinary means distinction is Daniel A. Cronin’s doctoral dissertation (1958) from the Gregorian Pontifical University in Rome: The Moral Law in Regard to the Ordinary and Extraordinary Means of Conserving Life. The author, now the Most Reverend Daniel A. Cronin, S.T.D., Bishop of Fall River, Massachusetts, (Archbishop of Hartford, CT, 1991, retired, 2003) presents a study of the views of fifty or more moral theologians from Thomas Aquinas to the early 1950’s, followed by his own recommendations. His position is presented here in two sections.

A. THE ORDINARY/EXTRAORDINARY
MEANS DISTINCTION

Following his discussion of the views of individual authors, Cronin attempts to summarize and categorize their positions by listing various features commonly cited as grounding the distinction between obligatory and optional means.³³ None of these features is employed by every author Cronin cites, but each of the features is employed by enough of the authors to justify calling it an important aspect of the distinction as it has been drawn historically.

Concerning the concept of ORDINARY (obligatory) means, Cronin mentions four commonly cited features:

(1) hope of a beneficial result (spes salutis): even natural means, such as the taking of food or drink, can become optional if this element is not present. Cronin sees this feature as relative to the condition of the patient, so that no means can be said to be absolutely obligatory regardless of the patient’s own status;

(2) commonly used (media communia): Cronin sees this notion of what is in common use as basic. “For the moralists, the duty of conserving one’s life does not demand a diligence or a solicitude that exceeds the usual care that most men normally give their lives.”³⁴

(3) comparison with one’s social position (secundum proportionem status): This feature serves to emphasize even further the relative feature of what is obligatory. Cronin sees this idea as connected with the idea of commonly used means and also with the feature of cost;

(4) not difficult to obtain and employ (medicina non difficilia): this feature is alternatively phrased positively as “convenient” means, though Cronin notes that most moralists prefer using the negative expression. The difficulty in question must be excessive, and, once again, this can be determined only as relative to the patient’s own condition.

In addition to characterizing ordinary means, the moralists have also used terms to refer to means held to be EXTRAORDINARY and therefore as OPTIONAL. Cronin lists five of these commonly used phrases:

(1) impossibility (quaedam impossibilitas): this feature refers to the element of moral as opposed to physical impossibility. We may characterize the morally impossible as what one cannot be reasonably expected to do. Again, this feature is relative to the condition of the patient;

(2) great effort (summus labor, media nimis dura): such a quality can encompass even the taking of food;

(3) pain (quidam cruciatus, ingens dolor): Cronin maintains that this should also be understood as relative to the patient’s.condition;

(4) expense (sumptus extraordinarius, media pretiosa, media exquisita): again, relative to the condition of the patient, though some authors, as we have noted, would permit some appeal to an absolute standard of expense beyond which no one need go;

(5) intense emotion (vehemens horror): fear and repugnance are the two emotions commonly appealed to. This feature is closely related to the first as creating a moral impossibility, and, like the first, is also a relative norm.

Turning from the more historical dimensions of his study, Cronin examines the views of Gerald Kelly. Cronin is generally favorable toward Kelly’s definitions of ordinary and extraordinary quoted above. Cronin’s definitions may be understood simply as clarifications of Kelly’s:

Ordinary means of conserving life are those means commonly used in given circumstances, which this individual in his present physical, psychological and economic condition can reasonably employ with definite hope of proportionate benefit.

Extraordinary means of conserving life are those means not commonly used in given circumstances, or those means in common use which this individual in his present physical, psychological condition cannot reasonably employ, or if he can, will not give him definite hope of proportionate benefit.³⁵

Cronin’s definitions provide two standards, one absolute and one relative. If a means is not ordinarily or customarily used, then no one has an obligation to employ it (in the absence of exceptional features). This is an absolute standard. The relative standard enters when a means is customarily employed, but would be unreasonable for that particular individual

B. SPECIAL OBLIGATIONS OF PHYSICIANS

With regard to the special obligations of physicians, Cronin maintains that the physician has the obligation of using ordinary means of conserving life when treating the patient, and that, If the patient chooses to employ extraordinary means the doctor has no choice but to follow his wishes. “In the last analysis, it is the patient who has the right to say whether or not he intends to use the extraordinary means of conserving life.”³⁶ This position, like Kelly’s, skirts the question of what the physician ought to do if the patient refuses ordinary (morally obligatory) means.

Cronin discusses a number of specific cases which permit him to illustrate principles regarding the special responsibilities of the physician . Cronin’s views are consistently patient-centered . A few of the rules he proposes as guides for the physician are:

(1) if it is unknown what means a patient would wish employed, the doctor’s duty does not extend to the use of extraordinary means, even if these would benefit the patient. “We are not bound in charity to force a neighbor to save his life by means which he, personally, is not bound to use to save his own life. ³⁷

(2) if the patient’s actual wishes cannot be ascertained, the physician should make a reasonable effort to determine what the patient would wish, were he able to respond;

(3) if relatives are present when the patient’s wishes cannot be ascertained, then they should try to make the decision for the patient and the doctor should follow their wishes;

(4) if no relatives or friends or guardians are present, then the doctor should decide on the basis of what he believes to be the greater good of the patient;

(5) the physician’s prime duty is to the patient and not the medical profession. The doctor should never judge that an unconscious or mentally incompetent patient or a patient receiving charity should be given extraordinary means merely for the advancement of scientific knowledge or because he believes that the professional ideal requires fighting death to the bitter end. Surreptitious experimentation carried on without informed consent by the use of extraordinary means is wrong. If the common good does not oblige the patient to use extraordinary means, that good cannot oblige the physician either.³⁸

Cronin writes:

In practice, therefore, a doctor should take his norm from the obligation of the patient himself. The doctor must employ the ordinary means of conserving life and then those extraordinary means which, per accidens, are obligatory for the patient or which the patient wants to use. He must never practice euthanasia and he must conscientiously strive never to give the impression of using euthanasia. Furthermore, he must strive to find a remedy for the disease. However, when the time comes that he can conserve his patient’s life only by extraordinary means, he must consider the patient’s wishes, expressed or reasonably interpreted, and abide by them. If the patient is incurable and even ordinary means, according to the general norm, have become extraordinary for this patient, again the wishes of the patient expressed or reasonably interpreted must be considered and obeyed.³⁹

The foregoing represents not only a summary of Cronin’s views but a remarkable recapitulation of the ideas that derive from a study of the historical development of the concept of obligatory and optional means of preserving life. That development, given its history of some five hundred years, is surprisingly consistent.⁴⁰ There are indeed differing emphases, and individual authors may disagree on specific points. But the overall appearance is one of uniformity and at times almost one of tedious repetition. No doubt changing circumstances require applications in novel areas, but the basic principles have been firmly laid in a coherent development stretching back at least to the time of Aquinas.

NOTES

33. Cronin, Daniel, The Moral Law in Regard to the Ordinary and Extraordinary Means of Conserving Life (Dissertatio ad Lauream in Facultate Theologica Pontificiae Universitatis Gregorianae, Romae, 1958) , pp. 98‑126.

34. ibid, p. 105.

35. ibid., pp. 127‑28.

36. ibid, p. 143.

37. ibid. pp. 145‑46.

38. ibid., pp. 155‑56.

39. ibid., p. 157.

40. This chapter concludes with the work of Gerald Kelly and Daniel Cronin which preceded the allocution of Pope Pius XII mentioned above in note 1.

Gerald Kelly (1902-1964)

Kelly is an important figure for this study. As a moral theologian he was intrigued by the history of the concept of ordinary and extraordinary means. He published two key articles in Theological Studies, “The Duty of Using Artificial Means of Preserving Life” (1950, hereafter “Artificial”)22 and “The Duty to Preserve Life” (1951, hereafter “Preserve”).23 The earlier article, “Artificial,” is the lengthier of the two. In it Kelly presented a resumé of the traditional position and requested help from his readers in resolving a few of the more difficult questions raised. The shorter, “Preserve,” appeared eighteen months later and contains Kelly’s further reflections on the topic in response to suggestions from his readers.

In the first article, Kelly summarized a descriptive approach to the distinction of ordinary and extraordinary means of prolonging life:

Speaking of the means of preserving life and of preventing or curing disease, moralists commonly distinguish between ordinary and extraordinary means. They do nor always define these terms, but a careful examination of their words and examples reveals substantial agreement on the concepts. By ordinary they mean such things as can be obtained and used without great difficulty. By extraordinary they mean everything which involves excessive difficulty by reason of physical pain, repugnance, expense, and so forth. In other words, an extraordinary means is one which prudent men would consider at least morally impossible with reference to the duty of preserving one’s life.24

Kelly also notes the uncertain status of major operations in these days of anesthesia and antibiotics. He finds a tendency among modern authors to consider most operations today as ordinary means, though there is also a common willingness to admit the possibility that a strong subjective repugnance on the part of the patient could render those operations extraordinary means for some people.

Kelly raises the question of whether the concept of the “extraordinary” should be treated as relative or absolute, a question raised already in this chapter. Kelly writes that his “general impression” is that “there is common agreement that a relative estimate suffices. In other words, if any individual would experience the inconvenience sufficient to constitute a moral impossibility in the use of any means, that means would be extraordinary for him.”25 On the other hand, Kelly cites a number of authors who believe that there is an absolute standard of an extraordinary means beyond which no one, regardless of his condition, need go.

Kelly makes two other points that should be mentioned here. First, he notes that the standard moralists he has consulted are concerned solely with the responsibility of the individual patient and say nothing about the duties of the family or of the medical profession. Second, Kelly points out that the moralists are in agreement that although a patient is per se not obliged to use extraordinary means in preserving his life, the use of such means is permissible and usually admirable. Furthermore, a patient per accidens may even be obliged to use extraordinary means “if the preservation of his life is required for some greater good such as his own spiritual welfare or the common good.” As traditionally cited examples, one might consider the obligation of a person to take extraordinary steps to preserve his life until he can receive the sacraments, or the obligation of a government leader to keep himself alive if his leadership is necessary for the welfare of the community.

The foregoing is relatively unproblematical, at least on a theoretical level. But Kelly continues in a way that will produce terminological difficulty. This occurs when Kelly raises the question whether a patient can be obliged to employ useless ordinary means. Kelly cites several authors including Alphonsus. Ballerini-Palmieri and Noldin-Schmitt, as seeming to espouse the view

that no remedy is obligatory unless it offers a reasonable hope of checking or curing a disease. I would not call this a common opinion because many authors do not refer to it, but I know of no one who opposes it, and it seems to have intrinsic merit as an application of the axiom, nemo ad inutile tenetur [i.e., No one can be obliged to do what is useless]. Moreover, it squares with the rule commonly applied to the analogous case of helping one’s neighbor: one is not obliged to offer help unless there is a reasonable assurance that it will be efficacious.26

Kelly is thus willing in “Artificial” to countenance the possibility of some means being ordinary and yet optional and non-obligatory. At the close of that article, Kelly admitted that many of the points he had raised call for further discussion. Two in particular, he said, were of “special import,” and one of these was the possibility “that even ordinary, artificial means are not obligatory when relatively useless.” His original article can be seen, then, as a call for further discussion on certain controversial issues.

In his second article, Kelly presents some of the reactions his earlier paper had elicited from theologians and offers further reflections of his own. He writes in “Preserve”:

Theologians have responded favorably to the suggestion that even an ordinary artificial means need not be considered obligatory for a patient when it is relatively useless. It was proposed, however,--and I agree with this--that, to avoid complications, it would be well to include the notion of usefulness in the definitions of ordinary and extraordinary means. This would mean that, in terms of the patient’s duty to submit to various kinds of therapeutic measures, ordinary and extraordinary means would be defined as follows:

Ordinary means are all medicines, treatments, and operations, which offer a reasonable hope of benefit and which can be obtained and used without excessive expense, pain, or other inconvenience.

Extraordinary) means are all medicines, treatments, and operations, which cannot be obtained and used without excessive expense, pain, or other inconvenience, or which, if used, would not offer a reasonable hope of benefit.

With these definitions in mind, we could say without qualification that the patient is always obliged to use ordinary means. On the other hand, insofar as the precept of caring for his health is concerned, he is never obliged to use extraordinary means; but he might have an extrinsic obligation to use such means, e.g., when his life is necessary for the common good or when a prolongation of life is necessary for eternal salvation.27

It will be helpful to compare these definitions of ordinary and extraordinary means with the descriptions cited from the first article above. There we see the term ordinary as encompassing only those means “as can be obtained and used without great difficulty.” The new definition of ordinary) is changed in two ways, one obvious and other more subtle. First, Kelly quite obviously adds the concept of usefulness to the definition of ordinary. But, secondly, there is a more radical change in the way in which the term ordinary is treated. In the earlier definition, the term is treated as descriptive term, as simply referring to how easily the means may be obtained and employed. In the latter definition, and the quotation makes this clear, Kelly treats the term as an essentially normative or evaluative e one. It is no longer used simply to describe ease of use; it is now used to make a judgment regarding obligatoriness of use. For the earlier definition, it made quite good sense to suggest as a theoretical possibility that some ordinary means might not be obligatory. But in the second definition, it makes no sense (at least in Kelly’s mind) to suggest an ordinary means (as newly defined) might not be obligatory: “without qualification the patient is always obliged to use ordinary means.” In other words, to call a means non-obligatory one must, using Kelly’s new definitions, call the means extraordinary. Ordinary = obligatory. extraordinary = per se optional, and these two equations are justified by reducing the obligatoriness of means to their being easily obtained and employed and their offering reasonable hope of benefit.

Kelly’s two articles mark, as it were, a kind of watershed between the descriptive and normative senses of ordinary and extraordinary. Writing in his first article and surveying the past history, Kelly could provide a descriptive analysis of ordinary. Writing in his second, in response to suggestions, he provides a normative analysis. Of course, this descriptive/normative distinction can be pushed too far, for even in the first definition the feature of “without great difficulty” has normative elements. And in the second, the elements of being without excessive burden and offering reasonable hope of benefit are somewhat descriptive. Nevertheless, the differences between the two definitions are sufficiently great to warrant calling them definitions of different types of concepts. Thus, the possibility of serious confusion is created when the same word is used to bear such fundamentally different meanings .

In his first article, in discussing the case of a dying patient whose life can be extended for a few weeks by intravenous feeding, Kelly holds that the issue comes down to the usefulness of the means. “To me, the mere prolonging of life in the given circumstances seems to be relatively useless, and I see no sound reason for saying that the patient is obliged to submit to it.”28 A conscious patient should be allowed to decide for himself. If unconscious, Kelly still says, “I see no reason why even the most delicate professional standard should call for their use. In fact, it seems to me that, apart from very special circumstances, the artificial means not only need not, but should not, be used, once the coma is reasonably diagnosed as terminal.”29

Kelly cites the positions of two earlier commentators on the case. The original commentator, Joseph P. Donovan, had held that the IV feeding itself involves no moral impossibility and hence should be considered an ordinary means. Stopping IV would, according to Donovan, be a form of mercy killing. 30 On the other hand, Joseph V. Sullivan had held the position that extraordinary means are relative to the patient’s condition, and, because IV feeding is an artificial means of prolonging life, one may be more liberal in application of principle.31 Therefore, Sullivan considers the means to be extraordinary and the physician to be justified in discontinuing the IV.

Kelly’s position is to offer a distinction. He is in agreement with Donovan in calling IV an ordinary means, but he says that “one may not immediately conclude that it is obligatory.” Rather, Kelly wishes to consider such means ordinary, but useless, artificial means of preserving life and so optional. Thus, Kelly is in practical agreement with Sullivan over the discontinuance of the means, but sides with Donovan on designating the means as ordinary. The strong impression conveyed is that both Sullivan and Donovan are using the concept of ordinary which Kelly later adopted in his second article. Under his revised conception, Kelly would have agreed with Sullivan in toto, calling the means useless, and therefore extraordinary, and therefore optional.

Kelly says that using oxygen or IV feeding merely to sustain life for a while in “hopeless” cases can be called remedies “only in the very wide sense that they delay the hour of death.” Because they sustain life, they in a sense offer a hope of success. But their expense quickly can mount up. For a combination of reasons, then, the use of artificial means of preserving life for a few days or weeks is optional.

Kelly notes that his principles embody a great deal of imprecision: There are degrees of “success.” It is one thing to use oxygen to bring a person through a crisis; it is another thing to use it merely to prolong life when hope of recovery is practically negligible. There are also degrees of “hope,” even when it concerns complete recovery. For example, in one case the use of oxygen to bring a

patient through a pneumonia crisis may offer very high hope, whereas in another case the physical condition of the patient may be such that there is only a slim chance of bringing him through the crisis. Finally, there are degrees of difficulty in obtaining and using ordinary means. Some are inexpensive and very easy to obtain and use; others may involve much more difficulty, though not moral impossibility.32

All of these features add considerably to the practical difficulties encountered in deciding about concrete cases. But they do not necessarily create theoretical problems of understanding.

Daniel A. Cronin (1927- )

The most complete work on the history of the ordinary/extraordinary means distinction is Daniel A. Cronin’s doctoral dissertation (1958) from the Gregorian Pontifical University in Rome: The Moral Law in Regard to the Ordinary and Extraordinary Means of Conserving Life. The author, now the Most Reverend Daniel A. Cronin, S.T.D., Bishop of Fall River, Massachusetts, presents a study of the views of fifty or more moral theologians from Thomas Aquinas to the early 1950’s, followed by his own recommendations. His position is presented here in two sections.

A. THE ORDINARY/EXTRAORDINARY MEANS DISTINCTION

Following his discussion of the views of individual authors, Cronin attempts to summarize and categorize their positions by listing various features commonly cited as grounding the distinction between obligatory and optional means.33 None of these features is employed by every author Cronin cites, but each of the features is employed by enough of the authors to justify calling it an important aspect of the distinction as it has been drawn historically.

Concerning the concept of ordinary (obligatory) means, Cronin mentions four commonly cited features:

(1) hope of a beneficial result (spes salutis): even natural means, such as the taking of food or drink, can become optional if this element is not present. Cronin sees this feature as relative to the condition of the patient, so that no means can be said to be absolutely obligatory regardless of the patient’s own status;

(2) commonly used (media communia): Cronin sees this notion of what is in common use as basic. “For the moralists, the duty of conserving one’s life does not demand a diligence or a solicitude that exceeds the usual care that most men normally give their lives.”34

(3) comparison with one’s social position (secundum proportionem status): This feature serves to emphasize even further the relative feature of what is obligatory. Cronin sees this idea as connected with the idea of commonly used means and also with the feature of cost;

(4) not difficult to obtain and employ (medicina non difficilia): this feature is alternatively phrased positively as “convenient” means, though Cronin notes that most moralists prefer using the negative expression. The difficulty in question must be excessive, and, once again, this can be determined only as relative to the patient’s own condition.

In addition to characterizing ordinary means, the moralists have also used terms to refer to means held to be extraordinary and therefore as optional. Cronin lists five of these commonly used phrases:

(1) impossibility (quaedam impossibilitas): this feature refers to the element of moral as opposed to physical impossibility. We may characterize the morally impossible as what one cannot be reasonably expected to do. Again, this feature is relative to the condition of the patient;

(2) great effort (summus labor, media nimis dura): such a quality can encompass even the taking of food;

(3) pain (quidam cruciatus, ingens dolor): Cronin maintains that this should also be understood as relative to the patient’s.condition;

(4) expense (sumptus extraordinarius, media pretiosa, media exquisita): again, relative to the condition of the patient, though some authors, as we have noted, would permit some appeal to an absolute standard of expense beyond which no one need go;

(5) intense emotion (vehemens horror): fear and repugnance are the two emotions commonly appealed to. This feature is closely related to the first as creating a moral impossibility, and, like the first, is also a relative norm.

Ordinary means of conserving life are those means commonly used in given circumstances, which this individual in his present physical, psychological and economic condition can reasonably employ with definite hope of proportionate benefit.

Extraordinary means of conserving life are those means not commonly used in given circumstances, or those means in common use which this individual in his present physical, psychological condition cannot reasonably employ, or if he can, will not give him definite hope of proportionate benefit.35

B SPECIAL OBLIGATIONS OF PHYSICIANS

With regard to the special obligations of physicians, Cronin maintains that the physician has the obligation of using ordinary means of conserving life when treating the patient, and that, If the patient chooses to employ extraordinary means the doctor has no choice but to follow his wishes. “In the last analysis, it is the patient who has the right to say whether or not he intends to use the extraordinary means of conserving life.”36 This position, like Kelly’s, skirts the question of what the physician ought to do if the patient refuses ordinary (morally obligatory) means.

( 1) if it is unknown what means a patient would wish employed, the doctor’s duty does not extend to the use of extraordinary means, even if these would benefit the patient. “We are not bound in charity to force a neighbor to save his life by means which he, personally, is not bound to use to save his own life. 37

(2) if the patient’s actual wishes cannot be ascertained, the physician should make a reasonable effort to determine what the patient would wish, were he able to respond;

(3) if relatives are present when the patient’s wishes cannot be ascertained, then they should try to make the decision for the patient and the doctor should follow their wishes;

(4) if no relatives or friends or guardians are present, then the doctor should decide on the basis of what he believes to be the greater good of the patient;

Cronin writes:

The foregoing represents not only a summary of Cronin’s views but a remarkable recapitulation of the ideas that derive from a study of the historical development of the concept of obligatory and optional means of preserving life. That development, given its history of some five hundred years, is surprisingly consistent.40 There are indeed differing emphases, and individual authors may disagree on specific points. But the overall appearance is one of uniformity and at times almost one of tedious repetition. No doubt changing circumstances require applications in novel areas, but the basic principles have been firmly laid in a coherent development stretching back at least to the time of Aquinas.

Notes

1. The Pope Speaks 4 (1958), 393-98.

2. St. Thomas Aquinas, Super Epistolas S. Pauli (Taurini-Romae, Marietti, 1953), II Thess., Lec. II, n. 77. Translation in: Cronin, Daniel, The Moral Law in Regard to the Ordinary and Extraordinary Means of Conserving Life (Dissertatio ad Lauream in Facultate Theologica Pontificiae Universitatis Gregorianae, Romae, 1958) p. 48.

3. Summa Theologica, Blackfriars Translation, Anthony Ross, O.P., and P.G.Walsh. (New York, McGraw-Hlll Book Co., 1966), II, II, q. 126, a. 1.

4. ibid. ad. 3.

5. For example, for the teaching of Thomas Aquinas on suicide, see II,II, q. 64, a. 5; for his teaching on killing the innocent: II,II, q. 64, a. 6; on self-detense: II,II, q. 64, a. 7 and 8; on mutilation: II,II, q. 65, a. 1.

6. F. Vitoria, Relectiones Theologicae, (Lugduni, 1587), Relectio IX, de Temp. n. 1, (Transl. as in Cronin, op. cit., pp. 48‑49).

7. ibid., n. 9 (Cronin, p. 49).

8. ibid., n. 12 (Cronin, p. 49).

9. F. Vitoria, Comentarios a la Secunda Secundae de Santo Tomcis (Salamanca, ed. de

Heredia, O.P., 195 2) in 11,11, q. 147, a. 1 (Transl. as in Cronin, p. 50).

10. F. Vitoria, Relectiones, Relectio X, de Homicidio, n. 35, (Transl. as in C ronin,

11. Cronin, op. cit., p. 90.

12. J. de Lugo, Disputationes Scholasticae et Morales (ed. nova, Parisiis, Vivès,1868‑69), Vol. VI, De iustitia et iure, Disp. X, Sec. 1, n. 21, (Transl. as in Cronin, p. 59).

13. Ibid., n. 32, 36.

14. Ibid., n. 30, (Transl. as in Cronin, p. 64).

15. Cronin, op. cit., p. 70.

16. V. Patuzzi, Ethica Christiana sive Theologia Moralis, (Bassani, 1770), Tom. III, Tract. V, Pars. V, Cap. X, Consect. sept.

17. Cronin, op. cit., p. 77.

18. H . Noldin and A. Schmitt, Summa Theologiae Moralis, 3 Vols., (Oeniponte, Rauch, 1940‑41), Vol. 2, p. 308.

19. E. Genicot and J. Salsmans, Inutitutiones Theologiae Moralis, 2 Vols., (Bruxelles, L’Edition Universelle, S.A., ed. 17, 19 5 1), Vol. 1, n. 364.

20. H. Jone and U. Adelman, Moral Theology (Westminster: Newman Press, 1948), n. 210.

21. E. Healy, Moral Guidance, (Chicago: Loyola University Press, 1942), p. 162.22. G. Kelly, “The Duty of Using Artificial Means of Preserving Life,” Theological Studies, XI (1950), pp. 203‑220.

23. G. Kelly, “The Duty to Preserve Life,” Theological Studies, XII (19 5 1), pp.550‑556.

24. Kelly, “Artificial,” p. 204.

25. ibid., p. 206.

26. ibid., p. 207‑08.

27. Kelly, “Preserve,” p. 55 0.

28. Kelly, “Artificial,” p.219.

29. ibid,, p. 220.

30. Homiletic and Pastoral Review, XLIX,(1949), p. 904.

31. J. Sullivan, Catholic Teaching on the Morality of Euthanasia, (The Catholic University of America Studies in Sacred Theology, Second Series, No. 22, Washington, D.C.: The Catholic University of America Press, 1949) p. 72.

32. Kelly, “Artificial,” p. 2 14.

33. Cronin, op. cit., pp. 98‑126.