McCaughey described Emanuel in a "New York Post" opinion article as a "Deadly Doctor" who advocated healthcare rationing by age and disability. Factcheck.org said this was incorrect and that "Emanuel's meaning is being twisted... he was talking about a philosophical trend, and... writing about how to make the most ethical choices when forced to choose which patients get organ transplants or vaccines when supplies are limited." An article in "Time" magazine said that Emanuel "was only addressing extreme cases like organ donation, where there is an absolute scarcity of resources", and quoted Emanuel as saying: "My quotes were just being taken out of context." The "New York Times" noted that Emanuel had opposed the legalization of euthanasia or physician-assisted suicide when such proposals were being debated in the late 1990s.