Dr. Jack Kevorkian is the name that is cited the most when euthanasia is discussed. He claims to have assisted more than 125 terminally ill patients to die peacefully. Pro-choice activists have always argued that when a person is terminally ill and is in a lot of pain he should be allowed the liberty to choose between life and death. Dr. Kevorkian and his ilk offer a painless death, usually via a drug overdose or withdrawal of life support. There have been documented cases of doctors writing 'do not resuscitate' in their notes in cases concerning terminally ill patients. It is unclear if this can be considered euthanasia.
Euthanasia can be also be non-voluntary when the patient lacks decision-making capacity and their proxies are not informed that the patient is going to be euthanized.