The events surrounding the withdrawal of a feeding tube from brain-damaged Terri Schiavo have highlighted the importance of health care planning. The lack of evidence concerning Schiavo’s intent with respect to the continuation or withdrawal of life-sustaining nutrition and hydration, complicated by the fact that she left no signed document or any clear previous oral statement, created a long and arduous legal battle among family members. Aside from the important policy implications of the Schiavo case, the case illustrates that health care planning in the event of incompetency should be a part of every estate plan.¹