KIE: Recent judicial decisions and medical articles reflect a lack of consensus regarding who should initiate hospital "do not resuscitate" (DNR) orders and on what indications. Annas believes that the courts and physicians are failing to distinguish the two fundamentally different reasons for which DNR orders are written. When cardiopulmonary resuscitation is contraindicated because poor prognosis renders medical intervention futile, the decision should properly be made by the physician. Decisions based on the patient's quality of life, however, should remain the exclusive province of the patient or his guardian. Three legal cases are cited to illustrate these points.