parties. Florida governor and executive Following the Supreme Court's refusal to review the case, Florida Governor Jeb Bush announced that he was going to investigate whether the Florida Department of Children and Families could take over Schiavo's care, on the grounds that the organization has the legal right to gain custody of incapacitated adults in emergency situations. On March 24, 2005, Judge Greer issued an injunction stopping the state government from doing so. Bush then announced that he would take no action, because he had exhausted his legal options, and declined to appeal Judge Greer's injunction. At the time, there was a great deal of concern over what would happen if the Florida Department of Law Enforcement (FDLE) or the Florida National Guard were ordered to take custody of Schiavo. As Greer had ordered all Florida law enforcement to enforce his orders, any attempt by other police forces to take Schiavo would likely have led to a confrontation between them and the members of the Pinellas Park Police Department at the hospice. If this had happened, it may have very well caused a constitutional crisis. Aftermath Terri Schiavo died on March 31, 2005, thirteen days after the removal of the feeding tube. Prior to and in the wake of Schiavo's death, end of life legislation has been proposed in at least ten states. These bills address the right to die as well as the right to life. Legislators are attempting to clarify the laws that govern the fate of a person in Schiavo's position, and in some cases make living wills more available. This could be partly because, as of 2005, it is estimated that only 33 percent of Americans have a living will (but all 50 states have laws that allow people to write an advance directive). States where new end of life legislation has been proposed includes: Alabama, Hawaii, Louisiana, Michigan, Minnesota, Missouri, Nevada, and South Dakota. Bills The Alabama Starvation and Dehydration Prevention Act would forbid the removal of a feeding tube without express written instructions from the patient. A similar bill is found in Louisiana, where it is named the Human Dignity Act. In Missouri, Republican Representative Cynthia Davis introduced a bill on the day Terri Schiavo died. Like other bills, her legislation would bar anyone from withholding or withdrawing artificial life support without a written directive from the patient. In Michigan, a legislator is proposing