The term 'right to die' has been interpreted in a number of ways, including issues of suicide, passive euthanasia, active euthanasia, assisted suicide, and physician-assisted suicide.[14] As health of citizens is considered a police power left for individual states to regulate, it was not until 1997 that the US Supreme Court made a ruling on the issue of assisted suicide and one's right to die. In 1997 the Supreme Court heard two appeals arguing that New York and Washington statutes that made physician assisted suicide a felony violated the equal protection clause of the Fourteenth Amendment.