Those who oppose active euthanasia believe that suicide goes against the sanctity of life. Floris Tomasini observes that the negative view of suicide has existed since the beginning of Christian theology which sees suicide as a sin (2014, p.100). For many people, this reason alone turns them away from PAS. Margaret Somerville pointed out that the arguments against physician-assisted suicide are not only religious, but also secular. He wrote that as human beings, we strive to find meaning in our lives. By shortening our lives (through active euthanasia), “we change the way we understand ourselves, human life and its meaning” (2003, p. 84). In other words, allowing PAS would devalue human life. Those on the opposite side of the debate argue that it is not the sanctity of life that should be taken into consideration, but the quality of life. Tomasini explains that the criteria on which the quality of life depends are health and happiness (2014, p.102). Those with a terminal illness often suffer and rely on medications. Richard T. Hull argues that it is not moral to keep people alive if they need to be constantly drugged to feel comfortable. In addition to not having health, most terminally ill patients do not have happiness. Vicki Lachman cited the Oregon Department of Human Services study on the Death with Dignity Act on the top three reasons why people would request PAS.