garments, which LDS hold sacred, as toilet tissue, and other similarly offensive actions. However, nearly every evangelical ministry, including those that actively challenge truth claims of Mormonism, vehemently condemns this sort of offensive and belligerent behavior, and further object to being placed in the same category as those few who engage in such behavior. As a result of organized protests at Mormon events, a number of Latter-day Saints, and even non-Mormons, have begun to counter-demonstrate at events (by singing hymns, for example). Secular anti-Mormonism Opposition to Mormonism has been more prominent in the 21st century from New Atheism perspectives. Richard Dawkins, Bill Maher and John Dehlin are among those who more prominent individuals who have used media appearances or podcasts to oppose the Institutional LDS Church and its doctrines and policies. Legal In March 2014, a court case was brought against LDS Church president Thomas S. Monson in the United Kingdom. Monson was accused by disaffected member Tom Phillips of breaching the Fraud Act 2006. The summons alleged that two men were induced to pay tithes to the LDS Church by church teachings which are objectively untrue. The alleged untrue teachings were: Joseph Smith translated the Book of Mormon from ancient gold plates and it is historically accurate; and Native Americans are descended from Israelites who left Jerusalem in 600 BC. The court case was tossed out before trial. The judges dismissed the case with stark language. Violence Tangible acts of violence against Latter-day Saints are considerably less common in the United States today than they were in the 19th century. The first significant violent persecution occurred in the early 1830s in Missouri. Mormons tended to vote as a bloc there, wielding "considerable political and economic influence," often unseating local political leadership and earning long-lasting enmity in the frontier communities. These differences culminated in the Missouri Mormon War and the eventual issuing of an executive order (since called the extermination order within the LDS community) by Missouri governor Lilburn Boggs, which declared that "the Mormons must be treated as enemies, and must be exterminated or driven from the State." Three days later, a renegade militia unit attacked a Mormon settlement at Haun's Mill, resulting in the death of 18 Mormons and no militiamen. The extermination order was not formally rescinded until 1976. After the destruction of the press of the Nauvoo Expositor in Nauvoo, Illinois, Joseph Smith was arrested and