While suicide must be honoured as a choice against an untenable life, checks & balances must be in place to guard against mistakes such as, Butler argues, those which occurred in the Janet Adkins case. Butler claims there were no checks & balances in her case & now there are more questions than answers – did Adkins understand the progress of Alzheimer’s & was she competent to make a decision to end her life? Butler says that this case should not be seen as a model for physician-assisted suicide.