elements, stating that euthanasia "must be defined as death that results from the intention of one person to kill another person, using the most gentle and painless means possible, that is motivated solely by the best interests of the person who dies." Prior to Draper, Beauchamp and Davidson had also offered a definition that included these elements. Their definition specifically discounts fetuses to distinguish between abortions and euthanasia:

Wreen, in part responding to Beauchamp and Davidson, offered