In the matter of Christine B. Biersach. In the Ohio Court of Appeals

HOLDING: Before withdrawal of tube feeding may be permitted, a guardian must establish, by clear and convincing evidence, the treating and consulting physicians' education, training, and experience; the physician's history and experience with the patient; the fact that the physician personally examined the patient; and the opinions required by statute. Each physician should also testify to his opinion that the other physician in the matter is qualified, by reason of advanced education or training, limited practice, experience, or certification as a specialist, to make the findings and provide the opinions about the patient which are required by the statute. The consulting physician's opinion should be more than a conclusory adoption of the attending physician's opinion. Rather, it should be independently stated and, ideally, should include the reasons upon which it is based.