Betsy McCaughey described Ezekiel Emanuel as a "Deadly Doctor" in a "New York Post" opinion article. The article, which accused Emanuel of advocating healthcare rationing by age and disability, was quoted from on the floor of the House of Representatives by Representative Michele Bachmann of Minnesota. Sarah Palin cited the Bachmann speech and said that Emanuel's philosophy was "Orwellian" and "downright evil", and tied it to a health care reform end of life counseling provision she claimed would create a "death panel". Emanuel said that Palin's death panel statement was "Orwellian".