Steinbock believes that Rachels is misinterpreting the American Medical Association’s (AMA) statement on euthanasia. According to her, the AMA is not making a distinction between active euthanasia (mercy killing) versus passive euthanasia (allowing a patient to die). Instead the distinction is between euthanasia of any kind, which the AMA forbids, and the withholding or cessation of life-prolonging treatment, which in some cases can be justifiable. In particular, Steinbock argues, the cessation of life-prolonging treatment is not the same as passive euthanasia in two kinds of cases. First, a patient may exercise her right to refuse treatment, even if treatment is necessary to prolong life. Second, in some cases, continued treatment may bring greater discomfort without much chance of improving the patient’s condition. In such cases, ceasing treatment is appropriate because the doctor is not intentionally terminating the patient’s life.