# Amicus Curiae Brief — Cruzan Ex Rel. Cruzan v. Director, Missouri Department of Health > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385012_0463%3A57 ## Record - **Collection:** Supreme Court brief - **Document type:** Amicus Curiae Brief - **Published:** January 1, 1990 - **Citation:** 497 U.S. 261 ## Text No. 88-1503 IN THE Supreme Court of the United States OCTOBER TERM, 1989 NANCY BETH CRUZAN, BY HER PARENTS AND CO-GUARDIANS, LESTER L. AND JOYCE CRUZAN, Petitioners, v. DIRECTOR OF MISSOURI DEPARTMENT OF HEALTH, AND ADMINISTRATOR OF THE MISSOURI REHABILITATION CENTER AT MT. VERNON, Respondents, V. THAD C. MCCANSE, GUARDIAN AD LITEM, Respondent, On Writ of Certiorari to the Missouri Supreme Court BRIEF OF RALPH BUGLIONI AS AMICUS CURIAE IN SUPPORT OF RESPONDENTS ROBERT L. SASSONE Attorney at Law 900 North Broadway « Suite 725 Santa Ana, California 92701 (714) 547-5611 MOTION FOR LEAVE TO FILE A BRIEF.AS AMICUS CURIAE ON BEHALF OF RESPONDENT Amicus hereby respectfully moves for leave to file a brief amicus curiae in the present case. Requested consent of the parties is expected but has not yet been received and filed. When filed, it will make this motion unnecessary. INTEREST OF AMICUS CURIAE Attorney herein was requested by the sister of Amicus who stated he only had a 30% chance to live a month to visit him at a Riverside, CA hospital. He was in acute intensive care, having had a severe heart attack six days previous. He could be understood, but spoke faintly. He had tubes at least in his veins and nose and numerous couplings to hospital equipment. He wanted you to understand that you do not have to kill. When a disabled patient is ready to die, he dies. He requests you to read the cautions to posterity herein written by Justice Robert Jackson. and Leo Alexander MD as they apply to euthanasia. TABLE OF CONTENTS MOTION FOR LEAVE TO FILE AND INTEREST OF AMICUS i TABLE OF AUTHORITIES ii SUMMARY OF ARGUMENT 1 ARGUMENT z 2 “HADAMAR TRIAL” FOREWORD BY THE HONORABLE ROBERT H JACKSON, 2 “MEDICAL SCIENCE UNDER DICTATORSHIP (FOOTNOTES HAVING BEEN DELETED) BY LEO ALEXANDER, MD, PSYCHIATRIST, 4 Preparatory Propaganda 6 Euthanasia 8 The Science of Annihilation 21 Medicomilitary Research 30 Motivation 39 The Early Change in Medical Attitudes 42 The Example of Successful Resistance by the Physicians of the Netherlands 44 The Situation in the United States 48 CONCLUSION 63 TABLE OF AUTHORITIES ITEM PAGE LEO ALEXANDER, MD, PSYCHIATRIST, OFFICIAL AMERICAN MEDICAL EXPERT AT THE NUREMBERG TRIALS;"MEDICAL SCIENCE UNDER DICTATORSHIP” (FOOTNOTES OMITTED) NE JOURNAL OF MEDICINE, 241:39-47, 1949 4 THE HONORABLE ROBERT H JACKSON, ASSOCIATE JUSTICE, US SUPREME COURT, AND FORMERLY US CHIEF OF COUNSEL FOR THE NUREMBERG TRIALS; HODGE & CO LTD, 1949 “THE HADAMAR TRIAL FOREWORD" 2 ii a 6 Pile ne Pee lt ee ae ad SUMMARY OF ARGUMENT. Should this Court accept "the atti- tude, basic in the euthanasia movement, that there is such a thing as life not worthy to be lived. This attitude in its early stages concerned itself merely with the severely and chronically sick." [From Alexander, infra). This Court is too young to include participants with expe- rience in the War Crimes trials such as the experience of those whose statements form this entire brief. Former Justice Robert Jackson and expert witnesses Alexander and Ivy would vote unanimously to affirm the Missouri decision which spared Nancy Cruzan's life, limited though her capabilities be. They were sufficiently concerned with you, their posterity, to state their reasons, based on the world's largest experiment with euthanasia, why you should not take even a first step toward euthanasia, no matter how compelling the reasons for said first step might appear. ARGUMENT THE HONORABLE ROBERT H JACKSON "A freedom-loving people will find in the records of the war crimes trials instruction as to the roads which lead to such a regime and the subtle first steps that must be avoided. Even the Nazis probably would have surprised themselves, and certainly they would have shocked many German people, had they proposed as a single step to establish the kind of extermination institution that the evi- dence shows the Hadamar Hospital became. But the end was not thus reached; it was achieved in easy steps. To begin with, it involved only the incurably sick, insane and mentally defi- cient patients of the Institution. It was x? Nee le wets ty we. - easy to see that they were a substantial burden to society, and life was probably of little comfort to them. It is not difficult to see how, religious scruples apart, a policy of easing such persons out of the world by a completely painless method could appeal to a hard-pressed and unsentimental people. But “euthanasia" taught the art of killing and accustomed those who directed and those who adminis- tered the death injections to the taking of human life. Once any scruples and in- hibitions about killing were overcome and the custom was established, there fol- lowed naturally an indifference as to what lives were taken. Perhaps also those who become involved in any killings are not to be in a good position to de- Cline further requests. If one is con- vinced that a person should be put out of the way because, from no fault of his i-. own, he has ceased to be a social asset, it is not hard to satisfy the conscience that those who are willful enemies of the prevailing social order have no better right to exist. And so Hadamar drifted from hospital to a human slaughter- — Foreword [From The Hadamar Trial/- by the Honorable Robert H Jackson, Associate Justice, U.S. Supreme Court, and formerly U.S. Chief of Counsel for the Nuremberg Trials, Hodge & Co Ltd., 1949] MEDICAL SCIENCE UNDER DICTATORSHIP by LEO ALEXANDER Science under dictatorship becomes subordinated to the guiding philosophy of the dictatorship. Irrespective of other ideologic trappings, the guiding philo- sophic principle of recent dictatorships, including that of the Nazis, has been a Hegelian in that what has been considered "rational utility" and corresponding doc- trine and planning has replaced moral, ethical and religious values. Nazi propa- ganda was highly effective in perverting public opinion and public conscience, in a remarkably short time. In the medical profession this expressed itself in a rapid decline in standards of profes- sional ethics. Medical science in Nazi Germany collaborated with this Hegelian trend particularly in the following en- terprises: the mass extermination of the chronically sick in the interest of sav- ing “useless" expenses to the community as whole; the mass extermination of those considered socially disturbing or ra- cially and ideologically unwanted; the individual, inconspicuous extermination of those considered disloyal within the ruling group; and the ruthless use of eH. "human experimental material for medi- comilitary research. This paper discusses the origins of these activities, as well as their conse- quences upon the body social, and the mo- tivation of those participating in them. Preparatory Propaganda Even before the Nazis took open charge in Germany, a propaganda barrage was directed against the traditional com- passionate nineteenth century attitudes toward the chronically ill, and for the adoption of a utilitarian, Hegelian point of view. Sterilization and euthanasia of persons with chronic mental illnesses was discussed at a meeting of Bavarian psy- chiatrists in 1931. By 1936 extermina- tion of the physically or socially unfit was so openly accepted that its practice was mentioned incidentally in an official German medical journal. As Lay opinion was not neglected in this campaign. Adults were propagandized by motion pictures, one of which, enti- tled “I Accuse,” deals entirely with euthanasia. This film depicts the life history of a woman suffering from multi- ple sclerosis; in it her husband, a doc- tor finally kills her to the accompani- ment of soft piano music rendered by a sympathetic colleague in an adjoining room. Acceptance of this ideology was im- planted even in the children. A widely used high school mathematics text, Mathematics in the Service of National Political Education, includes problems stated in distorted terms of the cost of caring for and rehabilitating the chroni- cally sick and crippled. One of the prob- lems asked, for instance, how many new housing units could be built and how many marriage-allowance loans could be given iy to newly wedded couples for the amount of money it cost to care for “the crippled, the criminal and the insane.” Euthanasia The first direct order for euthane- sia was issued by Hitler on September 1, 1939, and an organization was set up to execute the program. Dr. Karl Brandt headed the medical section, and Philip Bouhler the administrative section. All State institutions were required to re- port on patients who had been ill five yeayvS or more and who were unable to work, by filling questionnaires giving name, race, marital status, nationality, next of kin, whether regulariy visited and by who, who bore financial responsi- bility and so forth. The decision regard- ing which patients should be killed was made entirely on the basis of this brief information by expert consultants, most Ch awvt ax Pe ae s p hee vt et a Be) age le ey of whom were professors of psychiatry in the key universities. These consultants never saw the patients themselves. The thoroughness of their scrutiny can be ap- praised by the work of one expert, who between November 14 and December 1, 1940, evaluated 2109 questionnaires. These questionnaires were collected Work Committee of by a “Realm’s Institucions for Cure and Care.” A par- allel organization devoted exclusively to the killing of chi’dren was known by the Similarly euphemistic name of “Realm’s Committee for Scientific Approach to to Heredity and Severe Illness Due Constitution.” The “Charitable Transport Company for the Sick” transported pa- tients to the killing centers, and the “Charitable Foundation for Institutional Care” was in charge of collecting the cost of the killings from the relatives, . without, however, informing them what the charges were for; in the death certifi- cates the cause of death was falsified. What these activities meant to the population at large was well expressed by a few hardy souls who dared to protest. A member of the court of appeals at Frankfurt-am-Main wrote in December, 1939: There is constant discussion of the question of the destruction of socially unfit life — in the places where there are mental institutions, in neighboring Cowns, sometimes over a large area, throughout the Rhineland, for example. The people have come to recognize the vehicles in which the patients are taken from their original institution to the intermediate institution and from there to the liquidation institution. I am told that when they see these buses even the -10- children call out; ‘They’re taking some more people to be gassed.’ From Limburg it is reported that every day from one to three buses with shades drawn pass through on the way form Weilmunster to Hadamar, delivering inmates to the liquidation institution there. According to the stories the arrivals are immediately stripped to the skin, dressed in paper shirts and forthwith taken to a gas chamber, where they are liquidated with hydrocyanic acid gas and added anesthetic. The bodies are reported to be moved to a combustion chamber by means of a conveyor belt, six bodies to a furnace. The resulting ashes are then distributed into six urns which are shipped to the families. The heavy smcke form the crematory building is said to be visible over Hadamar every day. There is talk, furthermore, that in some cases heads and . other portions of the body are. removed for anatomical examination. The people working at this liquidation job in the institutions are said to be assigned from other areas and are ashamed completely by the populace. This personnel is described as frequenting the bars at night and drinking heavily. Quite apart from these overt incidents that exercise the imagination of the people, they are dis- quieted by the question of whether old folk who have worked hard all their lives and may merely have come into their dotage are also being liquidated. There is talk that the homes for the aged are to be cleaned out too. The people are said to be waiting for legislative regu- lation providing some orderly method that will insure especially that the aged feebleminded are included in the pro- gram." Here one sees what “euthanasia" means in actual piactice. According to the records, 275,000 people were put to death in these killing centers. Ghastly as this seems, it should be realized that this program was merely the entering wedge for exterminations of far greater scope in the political program for geno- cide of conquered nations and the ra- cially unwanted. The methods used and personnel trained in the killing centers for the chronically sick became the nu- cleus of the much larger centers in the East, where the plan was to kill all Jews and Poles and to cut down the Russian population by 30,000,000. The original program developed by Nazi hotheads included also the genocide of the English, with the provision that the English males were to used as labor- ers in the vacated territories in the yo —_— f East, there to be worked to’ death, whereas the English females were to be brought into Germany to improve the qual!- ities of the German race. (This was in- deed a peculiar admission on the part of the German eugenists.) In Germany the exterminations in- cluded the mentally defective, psychotics (particularly schizophrenics), epileptics and patients suffering from infirmities of old age and from various organic neu- “rologic disorders such as infantile paralysis, Parkinsonism, multiple sclero- sis and brain tumors. The technical ar- rangements, methods and.training of the killer personnel were under the direction of a committee of physicians and other experts headed by Dr. Karl Brandt. The mass killings were first carried out with carbon monoxide gas, but later cyanide gas (“cyclon B”) was found to be more ef- stn “ eres S| fective. The idea of camouflaging the gas chambers as shower baths was developed by Brack, who testified before Judge Sebring that the patients walked in calmly, de- posited their towels and stood with their little pieces of soap under the shower outlets waiting for the water to start running. This statement was ample rebut- tal of his claim that only the most severely regressed patients among the mentally sick and only the moribund ones among the physically sick were extermi- nated. In truth, all those unable to work and considered nonrehabilitable were killed. All but their squeal was utilized. However, the program grew so big that even scientists who hoped to benefit from the treasure of material supplied by this totalitarian method were disappointed. A neuropathologist. Dr. Hallervorden, who ie; had obtained 500 brains from the: killing centers for the insane, gave me a vivid firsthand The Charitable account. Transport Company for the Sick brought the brains in batches of 150 to 250 at a time. Hallervorden stated: There was wonderful materiel among those brains, beautiful mental defectives malformations and infantile early diseases. I accepted those brains of course. Where they came from and how they came to me was really none of my business. In addition to the material he wanted, all kinds of other cases were mixed in, such as patients suffering from various types of Parkinsonism, simple de- pressions, involutional depressions and brain’ tumors, and all kinds of other ill- nesses, including psychopathy that had difficult to handle: = * Rib wae Kat . aan These were selected from the various wards of the institutions according to an excessively simple and quick method. Most institutions did not have enough physicians, and what physicians there were were either too~ busy or did not care, and they delegated the selection to the nurses and attendants. Whoever looked sick or was otherwise a problem was put on a list and was transported to the killing center. The worst thing about this business was that it produced a certain brutalization of the nursing per- sonnel. They got to simply picking out those whom they did not like, and the doctors had so many patients that they did not even know them, and put their names on the list. Of the patients thus killed, only the brains were sent to Dr. Hallervorden; they were killed in such large numbers -17- ; eo a ae Eel ee Be - ————————————— that autopsies of the bodies were not feasible. That, in Dr. Hallervorden's opinion, greatly reduced the scientific value of the material. The brains, how- ever, were always well fixed and sus- pended in formalin, exactly according to his instructions. He thinks that the cause of psychiatry was permanently in- jured by these activities, and that psy- chiatrists have lost the respect of the German people forever. Dr. Hallervorden concluded: “Still, there were interesting cases in this material.” In general only previously hospitalized patients were ex- terminated for reasons of illness. An ex- ception is a program carried out in a northwestern district of Poland, the “Warthegau,” where a health survey of the entire population was made by an “S.S. X- Ray Battalion” headed by Professor Hohlfelder, radiologist of the University - os stn Seams PL PE eas, eae of Frankfurt-am-Main. Persons found to be infected with tuberculosis were carted off to special extermination centers. It is rather significant that the German people were considered by their Nazi leaders more ready to accept the ex- terminations of the sick than those for political reasons. It was for that reason that the first exterminations of the lat- ter group were carried out under the guise of sickness. So-called “psychiatric experts" were dispatched to survey the inmates of camps with the specific order to pick out members of racial minorities and political offenders from occupied territories and to dispatch them to killing center with epocialiy made diag- noses such as that of “inveterate German hater” applied to a number of prisoners who had been active in the Czech under- ground. = Certain classes of patients with mental diseases who were capable of per- forming labor, particularly members of the armed forces suffering from psychopa- thy or neurosis, were sent to concentra- tion camps to be exterminated in the pro- cess of removal of mine fields. A large number of those marked for death for political oF racial reasons were made available for "medical" experi- ments involving the use of involuntary human subjects. From 1942 on, such exper iments carried out in concentration camps were openly presented at medical meet~- ings. This program included “terminal hu- man experiments,” a term introduced by Dr. Rasher to denote an experiment So de- signed that its successful conclusion de- pended upon the test person's being put to death. -2%0- most likely silver nitrate with iodized oil, because the result could be’ ascer~ tained by X-ray examination. The injec~ tions were extremely painful, and a num- ber of women died in the course of the experiments. professor Karl Clauberg re~ ported that he had developed 4 method at the Auschwitz concentration camp by which he could sterilize 1000 women in one day. Another method of sterilization, oF rather castration, was proposed by Viktor Brack especially for conquered popula- tions. His idea was that X-ray machinery could be built into desks at which the people would have to sit, ostensibly to fill out 4 questionnaire requiring five minutes; they would be sterilized without being aware of it. This method failed because experiments carried out on 100 male prisoners brought out the fact that severe X-ray burns were produced on all -n2- oe “eae et ati ea Paks rt i. ae abs ae. subjects. In the course of this research, which was carried out by Dr. Horst Schuman, the testicles of the victims were removed for histologic examinations two weeks later- I myself examined four castrated survivors of this ghastly ex~ periment. Three had extensive necrosis of the skin near the genitalia, and the other an extensive necrosis of the urethra. Other experiments in steriliza- tion used an extract of the plant Caladium seguinum, which had been shown in animal studies by Madaus and his co- workers to cause selective necrosis of the germinal cells of the testicles as well as the ovary: The development of methods for rapid and inconspicuous individual execution was the objective of another large part of the ktenologic research. These methods were to be applied to members of the rul- -23- ing group, including the SS itself, who were suspected of disloyalty. This, of course, is an essential requirement in a dictatorship, in which "cutthroat compe- tition” becomes a grim reality, and any hint of faintheartedness or lack of en- thusiasm for the methods of totalitarian rule is considered a threat to the entire group. Poisons were the subject of may of these experiments. A research team at the Buchenwald concentration camp, consisting of Drs. Joachim Mrugowsky, Erwin Ding- Schuler and Waldemar Hoven, developed the most widely used means of individual exe- cution under the guise of medical treat- ment — namely, the intravenous injection of phenol or gasoline. Several alkaloids were also investigated, among them aconi- tine, which was used by Dr. Hoven to kill several imprisoned former fellow SS . 2 Bs A got oo men who were potential witnesses against the camp commander, Koch, then under in- vestigation by the SS. At the Dachau concentration camp Dr. Rascher developed the standard cyanide capsules, which could be easily bitten through, either deliberately or accidentally, if mixed with certain foods, and which, ironically enough, later became the means with which Himmler and Goering killed themselves. In connection with these poison experiments there is an interesting incident of char- acteristic sociologic significance. When Dr. Hoven was under trial by the SS the investigating SS judge, Dr. Morgen, proved Hoven’s guilt by feeding the poi- son found in Dr. Hoven's possession to a number of Russian prisoners of war; these men died with the same symptoms as the SS men murdered by Dr. Hoven. This worthy judge was rather proud of this efficient - 25- method of proving Dr. Hoven's guilt and appeared entirely unaware of the fact that in the process he had committed mur- der himself. Poisons, however, proved too obvious or detectable to be used for the elimina- tion of high-ranking Nazi party personnel who had come into disfavor or of promi- nent prisoners whose deaths shoula appear Phenol or to stem from natural causes. gasoline, for instance, left a telltale odor with the corpse. For this reason 4 number more subtle methocs were devised. One of these was artificial production of septicemia. An intramuscular injection of 1 cc. of pus, containing numerous chains of streptococci, was the first step. The site of injection was usually the inside close to the adductor of the thigh, canal. When an abscess formed it was tapped, and 3 cc. of the creamy pus re- gpa Bab kw Pelt gl moved was injected intravenously into the patient's opposite arm. If the patient then died from septicemia, the autopsy proved that death was caused by the same organism that had caused the abscesses. These experiments were carried out in many concentration camps. At the Dachau camp the subjects were almost exclusively Polish Catholic priests. However, since this method did not always cause death, sometimes resulting merely in a local ab- scess, it was considered inefficient, and research was continued with other means but along the same lines. The final triumph on the part of ktenologic research aimed at finding 4 method of inconspicuous execution that would produce autopsy findings indicative of death from natural causes was the de- velopment of repeated intravenous injec- tions of suspensions of live tubercle -27- bacilli, which brought on acute miliary tuberculosis within a few weeks. This method was produced by Professor Dr. Heissmeyer, who was one of Dr. Gebhardt’s associates at the SS hospital of Hohenlychen. As a4 means of further camou- flage, so that the SS at large would not suspect the purpose of these experiments, the preliminary tests for the efficiency of this method were performed exclusively on children imprisoned in the Neuengamme concentration camp. For use in “medical” executions of prisoners and of members of the SS and other branches of the German armed forces the use of simple lethal injections, par- ticularly phenol injections, remained the instrument of choice. Whatever methods he used, the physician gradually became the unofficial executioner, for the sake of convenience, informality and relative se- - 28 - crecy. Even on German submarines it was the physician’s duty to execute the trou- blemakers among the crew by lethal injec- tions. Medical science has for some time been an instrument of military power in that it preserved the health and fighting efficiency of troops. This essentially defensive purpose is not inconsistent with the ethical principles of medicine. In World War I the German empire had en- listed medical science as an instrument of aggressive military power by putting it to use in the development of gas war~ fare. It was left to the Nazi dictator~ ship to make medical science into an in- strument of political power — 4 formidable, essential tool in the com- plete and effective manipulation of to- talitarian control. This should be 4 warning to all civilized nations, and -29- particularly to individuals who are blinded by the “efficiency” of totalitar- jan rule, under whatever name. This entire body of research as re~ ported so far served the master crime to which the Nazi dictatorship was committed — namely, the genocide of non-German peo- ples and the elimination by killing, in groups or singly, of Germans who were considered useless or disloyal. in. eft- fecting the two parts of this program, Himmler demanded and received the cooper~ ation of physicians and of German medical science. The result was 4 significant advance in the science of killing or ktenology. : Medicomilitary research Another chapter in Nazi scientific research was that aimed to aid the mili- tary forces. Many of these ideas origi- nated with Himmler, who fancied himself a scientist. When Himmler learned that the cause of death of most SS men on the battie- field was hemorrhage, he instructed Dr. Sigmund Rascher to search for 4 blood co- agulant that might be given before the men went into action. Rascher tested this coagulant when it was developed by clocking the number of drops emanating from freshly cut amputation stumps of living and conscious prisoners at the crematorium of ester concentration camp and by shooting Russian prisoners of war through the spleen. Live dissections were 4 feature of another experimental study designed to show the effects of explosive decompres~ sion. A mobile decompression chamber was used. It was found that when subjects were made to ascend from altitudes of -31- 40,000 to 60,000 feet without oxygen, se~- vere symptoms of cerebral dysfunction oc- curred — at first convulsions, then un- consciousness in which the body was hang- ing limp and later, after wakening, tem- porary blindness, paralysis or sever con~ fusional twilight staces. Rascher, who wanted to find out whether these symptoms were due to anoxic changes or to other causes, did what appeared to him the most simple thing: he placed the subjects of the experiment under water and dissected them while the heart was still beating, demonstrating air embolism in the blood vessels of the heart, liver, chest wall and brain. Another part of Dr. Rasher’s re~ search, carried out in collaboration with Holzloehner and Finke, concerned shock from exposure to cold. It was known that military personnel generally did not sur~ -32- vive immersion in the North Sea for more than sixty to a hundred minutes. Rascher therefore attempted to duplicate these conditions at Dachau concentration camp and used about 300 prisoners in experi- ments on shock from exposure to cold; of these 80 or 90 were killed. (The figures do not include persons killed during mass experiments on exposure to cold out- doors.) In one report on this work Rascher asked permission to shift these experiments from Dachau to Auschwitz, 4 larger camp where they might cause less disturbance because the subjects shrieked from pain when their extremities froze white. The results, like so many of those obtained in the Nazi research program, are not dependable. In his report Rascher stated that it took from fifty-three to a hundred minutes to kill a human by immer- sion in ice water — a time closely in -%8- agreement with the known survival period in the North Sea. Inspection of his own experimental -ecords and statements made to me by his close associates showed that it actually took from eighty minutes to five or six hours to kill an undressed person in such a manner, whereas a man in full aviator's dress took six or seven hours to kill. Obviously, Rascher dressed up his findings to forestall criticism, although any scientific man should have known that during actual exposure many other factors, including greater convec- tion of heat due to the motion of water, would affect the time of survival. Another series of experiments gave results that might have been an important medical contribution if an important lead had not been ignored. The efficacy of various vaccines and drugs against typhus was tested at the Buchenwald and -34- Natzweiler concentration camps. Prevaccinated persons and annrendeteanes controls were injected with live typhus rickettsias, and the death rates of the series compared. After a certain number Of passages, the Matelska Strain of ty- phus rickettsia proved to become aviru- lent for man. Instead of seizing upon this as a possibility to develop a live vaccine, the experimenters, including the chief consultant, Professor Gerhard Rose, who should have known better, were merely annoyed at the fact that the controls did not die either, discarded this strain and continued testing their relatively inef- fective dead vaccines against a new viru- lent strain. This incident shows that the basic unconscious motivation and at- titude has a great influence in determin- ing the scientist's awareness o° the phe- nomena that pass through his vision -35- Sometimes human subjects were used for tests that were totally unnecessary, or whose results could have been pre- dicted by simple chemical experiments. For example, 90 gypsies were given unal- tered sea water and sea water whose taste was camouflaged as their sole source of fluid, apparently to test the well known fact that such hypertonic saline solu- tions given as the only source of supply of fluid will cause severe physical dis- turbance or death within six to twelve days. These persons were subjected to the tortures of the damned, with death re- sulting in at least two cases. Heteroplastic transplantation exper- iments were carried out by Professor Dr. Karl Gebhardt at Himmler’s suggestion. Whole limbs - shoulder, arm, or leg - were amputated from live prisoners at Ravensbrueck concentration camp, wrapped