statehood for Utah. The Smoot Hearings in 1904, which documented that the LDS Church was still practicing polygamy spurred the LDS Church to issue a Second Manifesto again claiming that it had ceased performing new plural marriages. By 1910 the LDS Church excommunicated those who entered into, or performed, new plural marriages. Even so, many plural husbands and wives continued to cohabit until their deaths in the 1940s and 1950s. Enforcement of the 1890 Manifesto caused various splinter groups to leave the LDS Church in order to continue the practice of plural marriage. Polygamy among these groups persists today in Utah and neighboring states as well as in the spin-off colonies. Polygamist churches of Mormon origin are often referred to as "Mormon fundamentalist" churches even though they are not parts of the LDS Church. Such fundamentalists often use a purported 1886 revelation to John Taylor as the basis for their authority to continue the practice of plural marriage. The Salt Lake Tribune stated in 2005 that there were as many as 37,000 fundamentalists with less than half of them living in polygamous households. On 13 December 2013, US Federal Judge Clark Waddoups ruled in Brown v. Buhman that the portions of Utah's anti-polygamy laws which prohibit multiple cohabitation were unconstitutional, but also allowed Utah to maintain its ban on multiple marriage licenses. Unlawful cohabitation, where prosecutors did not need to prove that a marriage ceremony had taken place (only that a couple had lived together), had been the primary tool used to prosecute polygamy in Utah since the 1882 Edmunds Act. Mormon fundamentalism The Council of Friends (also known as the Woolley Group and the Priesthood Council) was one of the original expressions of Mormon fundamentalism, having its origins in the teachings of Lorin C. Woolley, a dairy farmer excommunicated from the LDS Church in 1924. Several Mormon fundamentalist groups claim lineage through the Council of Friends, including but not limited to, the Fundamentalist Church of Jesus Christ of Latter Day Saints (FLDS Church), the Apostolic United Brethren, the Centennial Park group, the Latter Day Church of Christ, and the Righteous Branch of the Church of Jesus Christ of Latter-day Saints. Community of Christ The Community of Christ, known as the Reorganized Church of Jesus Christ of Latter Day Saints (RLDS Church) prior to 2001, has never sanctioned polygamy since its foundation in 1860. Joseph Smith III, the first Prophet-President