to outlaw the practice was endorsed as constitutional in 1878 by the Supreme Court in Reynolds v. United States, despite the religious objections of the Church of Jesus Christ of Latter-day Saints (Mormons). This Church subsequently ended the practice of polygamy around the turn of the twentieth century; however, several smaller fundamentalist Mormon groups across the state (not associated with the mainstream Church) continue the practice. On 13 December 2013, a federal judge, spurred by the American Civil Liberties Union and other groups, struck down the parts of Utah's bigamy law that criminalized cohabitation, while also acknowledging that the state may still enforce bans on having multiple marriage licenses. This decision was overturned by the United States Court of Appeals for the Tenth Circuit, thus effectively recriminalizing polygamy as a felony. In 2020, Utah voted to downgrade polygamy from a felony to an infraction, but it remains a felony if force, threats or other abuses are involved. Prosecutors in Utah have long had a policy of not pursuing polygamy in the absence of other associated crimes (e.g. fraud, abuse, marriage of underage persons, etc.). There are about 30,000 people living in polygamous communities in Utah. Individualist feminism and advocates such as Wendy McElroy and journalist Jillian Keenan support the freedom for adults to voluntarily enter polygamous marriages. Authors such as Alyssa Rower and Samantha Slark argue that there is a case for legalizing polygamy on the basis of regulation and monitoring of the practice, legally protecting the polygamous partners and allowing them to join mainstream society instead of forcing them to hide from it when any public situation arises. In an October 2004 op-ed for USA Today, George Washington University law professor Jonathan Turley argued that, as a simple matter of equal treatment under the law, polygamy ought to be legal. Acknowledging that underage girls are sometimes coerced into polygamous marriages, Turley replied that "banning polygamy is no more a solution to child abuse than banning marriage would be a solution to spousal abuse". Stanley Kurtz, a conservative fellow at the Hudson Institute, rejects the decriminalization and legalization of polygamy. He stated: In January 2015, Pastor Neil Patrick Carrick of Detroit, Michigan, brought a case (Carrick v. Snyder) against the State of Michigan that the state's ban of polygamy violates the Free Exercise and Equal Protection Clause of the U.S. Constitution. The case was dismissed with prejudice on 10 February