Similarly, Emanuel argues that there are four major arguments presented by opponents of euthanasia: a) not all deaths are painful; b) alternatives, such as cessation of active treatment, combined with the use of effective pain relief, are available; c) the distinction between active and passive euthanasia is morally significant; and d) legalising euthanasia will place society on a slippery slope, which will lead to unacceptable consequences. In fact, in Oregon, in 2013, pain wasn't one of the top five reasons people sought euthanasia. Top reasons were a loss of dignity, and a fear of burdening others.