In Terri's case, we might be able to ascertain the truth/falshood of this statement if Michael had used her rehabilitation funds for rehabilitation instead of legal fees - all the while pointing to her lack of improvement (as a result of his misappropriation of her funds) as a reason to kill her. The very cause for which he fights - to end her life - is arguably the reason she has not recovered.
The sickness of this defies words.
Since this argument is not new, I suspect that some court along the way has had the opportunity to find such uses to be "misappropriation" and declined to do so. Is it possible that it wasn't misappropriation?