fines. Thomas Jefferson suggested castration as the punishment for sodomy, rape, and polygamy in a proposed revision of the Virginia criminal code near the end of the 18th century. Pennsylvania was the first state to repeal the death penalty for "sodomy" in 1786 and within a generation all the other colonies followed suit (except North and South Carolina that repealed after the Civil War). Along with the removal of the death penalty during this generation, legal language shifted away from that of damnation to more dispassionate terms like "unmentionable" or "abominable" acts. Aside from sodomy and "attempted sodomy" court cases and a few public scandals, homosexuality was seen as peripheral in mainstream society. Lesbianism had no legal definition largely given Victorian notions of female sexuality. A survey of sodomy law enforcement during the nineteenth century suggests that a significant minority of cases did not specify the gender of the "victim" or accused. Most cases were argued as non-consensual or rape. The first prosecution for consensual sex between people of the same gender was not until 1880. In response to increasing visibility of alternative genders, gender bending, and homosexuality, a host of laws against vagrancy, public indecency, disorderly conduct, and indecent exposure was introduced across the United States. "Sodomy" laws also shifted in many states over the beginning of the twentieth century to address homosexuality specifically (many states during the twentieth century made heterosexual anal intercourse legal). In some states, these laws would last until they were repealed by the Supreme Court in 2003 with the Lawrence decision. Male ideal and the 19th century Male homosexuality found its first social foothold in the 19th Century not in sexuality or homoerotica, but in idealized conception of the wholesome and loving male friendship during the 19th century. Or as contemporary author Theodore Winthrop in Cecil Dreeme writes, "a friendship I deemed more precious than the love of women." This ideal came from and was enforced by the male-centric institutions of boy's boarding schools, all-male colleges, the military, the frontier, etc.—fictional and non-fiction accounts of passionate male friendships became a theme present in American Literature and social conceptions of masculinity. New York, as America's largest city exponentially growing during the 19th Century (doubling from 1800–20 and again by 1840 to a population of 300,000), saw the beginnings of a homosexual subculture concomitantly growing with the population. Continuing the theme of loving male friendship, the