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The way Terri Schiavo's private tragedy has become a political issue in the U.S. estranges many people in Europe. But Europeans, too, have struggled to find the proper balance between the right to life and the right to die. In 1974, Dutch mother-to-be Ineke Stinissen fell into a deep coma after problems with the anesthetic administered during her caesarean section. A year later, her husband Gerard asked that her feeding tube be removed, seeing no hope of her regaining consciousness. Stinissen's doctors refused on ethical grounds. Amid impassioned public debate, Gerard fought for his wife's right to die until late 1989, when a Dutch court ruled that tube feeding constitutes a medical treatment that can be withdrawn when there is no reasonable chance of recovery. Gerard found another doctor who, after determining that his wife was in a persistent vegetative state (PVS), agreed to remove the tube. Eleven days later, Ineke Stinissen died.

These days in the Netherlands and across much of Europe, divisions over euthanasia have largely healed. Polls in the U.K. and France show up to 80% support for legal changes that would allow patients enduring extreme suffering from a terminal illness to request medical assistance to shorten their lives. "The consensus in the Netherlands is that we don't prolong life just because we technically can," explains Johan Legemaate, legal adviser to the Royal Dutch Medical Association. "When a treatment does not improve the patient's situation, a doctor is obliged to stop it."

By this measure, the Schiavo case is straightforward. The patient has no chance of recovery, her husband has asked for her feeding tube to be removed, and Schiavo's doctors and the Florida state courts have approved that request. In the U.S., though, religion and faith-based politics intervene in a way that baffles Europeans. "It would have been handled very differently in Europe," says Wim Distelmans, chairman of the Federal Commission of Euthanasia in Belgium, where euthanasia is permitted if performed by a doctor after an adult patient clearly states a wish to die. "Because of the politics, it's now impossible to have a sensible debate on the issue in the U.S." Writing in the Times of London last week, foreign editor Bronwen Maddox said the Schiavo case "shows just how emphatically the U.S. and Europe are moving on different paths" on moral and social issues.

The debate in Europe centers less on whether euthanasia is right or wrong than on how to regulate it. Yet there are striking differences in terminology and approach. In the Netherlands, a medical treatment can be terminated when it is no longer "meaningful." In Switzerland, where assisted suicide is legal under certain conditions, euthanasia is still forbidden. In practice, though, voluntary euthanasia — when a doctor ends a patient's life with his or her consent — is common. A 2003 University of Zurich study showed that 7 out of 10 terminally ill Swiss resorted to voluntary euthanasia by, for example, ingesting a lethal dose of drugs or asking to have life-support systems disconnected. The practice remains illegal in France, though a draft "right-to-die" law was passed last November in the National Assembly and will be debated by the Senate later this year. If approved, it will "essentially give permission for doctors to stop treatment," says Dr. Jean Cohen, chairman of France's Association for the Right to Die with Dignity.

The French law was drafted in the wake of the controversial case of Vincent Humbert, who was left blind, paralyzed and mute after a 2000 auto accident. "France's general perception of what is going on in the Schiavo case is similar to the general mood with Humbert," says Cohen. "Most here have compassion for the patient, and are in favor of allowing death because they understand there is no point in living in this state." There is a difference, though. Vincent Humbert expressed a clear will to die. He dictated an acclaimed book, I Ask the Right to Die, by using small movements of one thumb. Terri Schiavo has given no such indication, according to her parents, though her husband claims she would want to be allowed to die. Still, says Cohen, "if there is no change in the state of a person for 15 years, enough is enough. You have to let go."

That's also the feeling in Britain, where courts must decide on a case-by-case basis whether nutrition and hydration can be denied to patients in a PVS. Courts are also involved in resolving disagreements on whether treatment should be withheld from critically ill patients. Last year, Elizabeth Butler-Sloss, president of the High Court Family Division, ruled that doctors had the right to deny 9-month-old Luke Winston-Jones mechanical ventilation if he stopped breathing, despite his mother's insistence on intervention. Winston-Jones was born with a rare genetic condition that left him with holes in his heart. If his condition deteriorated, doctors wanted to allow Luke to die; last November he did. A similar case is currently going through the British courts involving Charlotte Wyatt, a 17-month-old girl suffering from serious brain, lung and kidney damage. Physicians say the child, who's already been resuscitated three times, should not be revived again; the parents disagreed and have been back to court with evidence that the baby's condition had improved. A ruling is expected in April.

The Schiavo case could not happen in Germany, according to Dr. Jörg-Dietrich Hoppe, president of the Federal Chamber of Doctors, because treatment would only be withdrawn when a patient has clearly expressed the wish to die. "We agree with the part of Schiavo's family that wants life-saving treatment to be continued because at the moment she is not terminally ill," Hoppe says. "If it could be proved that [Schiavo] had expressed a wish that treatment should be stopped, that would be a different matter."

Some Europeans argue that removing Schiavo's feeding tube is cruel. "Being starved and dehydrated is not a death with dignity," says Tara Flood, spokesperson for Britain's Disability Awareness in Action. Others would welcome more American-style pro-life passion. Italy's Minister for European Affairs, Rocco Buttiglione, who last year was forced to withdraw his candidacy as the European Union's Commissioner for Justice after making controversial remarks on homosexuality and the role of women, applauds American politicians' intervention in the Schiavo case. "It's moving to see a great participation of the American people and great movement for life," Buttiglione told Time. "It will strengthen the position of those opposing euthanasia in Europe and start a debate here."

But so far, there is little evidence of one. Ten years ago, Pope John Paul II signed the encyclical Evangelium Vitae, which deemed euthanasia a "crime that no human law can claim to legitimize." "There is no obligation in conscience to obey such laws," the encyclical reads. "Instead, there is a grave and clear obligation to oppose them by conscientious objection." Many Europeans, though, seem content to leave harrowing decisions like those in the Schiavo case to the consciences of families and physicians.

• SIMON ROBINSON
• The Terri Schiavo case has provoked a fierce debate about euthanasia in the U.S. — and a sense of bafflement among many Europeans