. In addition, such cases are usually very complex medically and the complexity may not be able to be untangle by the judicial process. Finally, “a suit to enforce a living will is usually a sign that horrible and irreconcilable differences polluted efforts to make decisions for a patient” (Schneider. 11). Or, as he summarizes, “In love and death alike, not all wrongs can be righted, and yet fewer can be righted by the law” (p 11). Thus for the most part, the courts have allowed and occasionally encouraged the process in which healthcare, patients, and families work together to come to a consensus about what type of end-of-life care should be provided.