As legal scholar Susan Stefan writes: "Justice Rehnquist's short, curt opinion reversing "Quill" is almost angry." Rehnquist writes that assisted suicide is completely different from allowing a patient to refuse treatment. The difference is that with assisted suicide, the doctor means to cause the patient's death. When the doctor gives the patient medication that will kill them, they are "causing" the patient's death. When a doctor lets a patient refuse treatment, they are letting the patient's "disease" cause their death.