According to the AP, a couple in Eugene, Oregon were not non-creedal. After they argued a while about a Bible verse, the woman poured hot cooking oil on the man.

Knowing and loving Oregon as I do, right up there with France, I figure this was illegal because they were discussing the Bible. Therefore, it was a hate crime.

If she had just made a rational decision that the boyfriend was a waste of oxygen, she could have claimed it was euthanasia, highly favored in Oregon. "He was lying so still, I figured he must be dying, and I just eased him on his way. Yes, the screams concerned me, but I think they were an involuntary reflex after death, a celebration of the release of the spirit."