The Ashkenazi rabbi Moses Isserles disagreed with Karo and encouraged kapparot. In Ashkenazi communities especially, Rabbi Isserles' position came to be widely accepted, since Ashkenazi Jews will generally follow the halachic rulings of Rabbi Isserles where the Sephardic and Ashkenazic customs differ. It was also approved by Asher ben Jehiel (c. 1250–1327) and his son Jacob ben Asher (1269–1343) and other commentators. The ritual was also supported by Kabbalists, such as Isaiah Horowitz and Isaac Luria, who recommended the selection of a white rooster as a reference to and who found other mystic allusions in the prescribed formulas. Consequently, the practice became generally accepted among the Ashkenazi Jews and Hasidim of Eastern Europe. The Mishnah Berurah agrees with Rabbi Isserles, solidifying support for the practice among Lithuanian Jews as well. The Mishnah Berurah only supports the use of money (i.e., not a chicken) if there might be a problem with the slaughter due to haste or fatigue. In the late 19th-century work Kaf Hachaim, Yaakov Chaim Sofer approves of the custom for Sephardi Jews as well. Animal cruelty controversy Some Jews also oppose the use of chickens for kapparot on the grounds of tza'ar ba'alei chayim, the principle banning cruelty to animals. On Yom Kippur eve 2005, a number of caged chickens were abandoned in rainy weather as part of a kapparot operation in Brooklyn, New York; some of these starving and dehydrated chickens were subsequently rescued by the American Society for the Prevention of Cruelty to Animals. Jacob Kalish, an Orthodox Jewish man from Williamsburg, Brooklyn, was charged with animal cruelty for the drowning deaths of 35 of these kapparot chickens. In response to such reports of the mistreatment of chickens, Jewish animal rights organizations have begun to picket public observances of kapparot, particularly in Israel. Proponents of the kapparot ritual in the United States argue the practice to be constitutionally protected as an exercise of freedom of religion in the United States, which is further supported by a 1993 Supreme Court of the United States decision in the case of Church of the Lukumi Babalu Aye v. City of Hialeah. In that case, the court upheld the right of Santería adherents to practice ritual animal sacrifice, with Justice Anthony Kennedy stating in the decision, "Religious beliefs need not be acceptable, logical, consistent or comprehensible to others in order to merit First Amendment protection" (quoted by Justice Kennedy from