The concept of a living will was first put forward by Louis Kustner in the year 1969. Available statistics indicate that less than a quarter of the American population has a living will. However, an overwhelming number of people have responded to the idea of having one created. This can be attributed to the awareness, interest and even outrage generated by the Teri Schiavo incident, which managed to occupy the front pages of newspapers across the country for several weeks. A controversy was created when the court passed the final verdict, ordering her life support systems to be removed. It has been argued that what happened to Teri Schiavo was unfair and that she should have had a say in her medical treatment. This event acted as an eye opener to several people.