Although the Hippocratic Oath contained no mention of patient desires for medical treatment, the goal of medicine has always been to provide treatment in the best interests of the patient, and it was the physician who was responsible for the medical welfare of the patient. As autonomy developed in the Western world and values shifted toward personal responsibility and individuality, the concept of self-determination in medical decision-making became more important to society. Unethical research studies, both at home and abroad, along with prominent legal cases were now in the general public’s limelight. Discussions began to focus on informed consent and the patient’s right to accept, refuse, or withdraw medical treatment recommendations. In 1967, attorney Luis Kutner, who represented the Euthanasia Society of America, first introduced the concept of a living will and suggested people should document their preferences for medical treatment similar to a last will and testament. The Euthanasia Society developed the first living will format with simple wording expressing the preference to be allowed to die without heroic measures when there is no reasonable expectation for recovery. Unfortunately, these first forms were a request and not a legal document.