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D. Futile Care Theory. There are no laws permitting non-voluntary euthanasia in the United States, but it can probably be said that the same result occurs under Futile Care Theory. Futile Care Theory says that health care providers and institutions may deny treatment to people who are deemed not to have a quality of life worth preserving.  This is applicable even if the care is wanted and would benefit the patient.  The doctor is entitled to call such care inappropriate.  How Futile Care Theory Works In Practice.  Burke Balche. National Right to Life’s Medical Ethics Director, Burke Balche describes the dispute process (personal pre-interview note to Don Nelson, 09/04 to prepare for a Voice For Life Intereview):  “In the event of a dispute over providing wanted life-sustaining treatment, the matter will first be discussed informally among bioethics, chaplains, social workers, doctors, family, and patient (if capable). “If the dispute cannot be resolved informally, it will be brought to the hospital bioethics committee or other body established for "adjudication." “The committee hears from the doctors, family, bioethics experts, and others. If the committee rules that the treatment is not to be provided, the patient will be denied all further treatment in the hospital, other than comfort care--this, even if the family finds a doctor willing to provide the desired services.” This has become standard of practice in all 50 states.  If a lawsuit were to occur, it is likely that judges would ask if the hospital were following standard of care.  This is why Futile Care Theory is a very hot topic in bio-ethics and the right to life movement