taken effect. United States The United States government played an active role in the drafting of the convention and signed it on 16 February 1995, but has not ratified it. It has been claimed that American opposition to the convention stems primarily from political and religious conservatives. For example, The Heritage Foundation considers that "a civil society in which moral authority is exercised by religious congregations, family, and other private associations is fundamental to the American order", and the Home School Legal Defense Association (HSLDA) argues that the CRC threatens homeschooling. Most notably, at the time several states permitted the execution and life imprisonment of juvenile offenders, a direct contravention of Article 37 of the convention. The landmark 2005 Supreme Court decision in Roper v. Simmons declared juvenile executions to be unconstitutional as "cruel and unusual punishment"; in the 2012 case Miller v. Alabama, the court held that mandatory sentences of life without the possibility of parole are unconstitutional for juvenile offenders. State laws regarding the practice of closed adoption may also require an overhaul in light of the Convention's position that children have a right to identity from birth. During his 2008 campaign for President, Senator Barack Obama described the failure to ratify the convention as "embarrassing" and promised to review the issue but, as President, he never did. No President of the United States has submitted the treaty to the United States Senate requesting its advice and consent to ratification since the US signed it in 1995. The United States has ratified two of the optional protocols to the convention: the Optional Protocol on the Involvement of Children in Armed Conflict, and the Optional Protocol on the Sale of Children, Child Prostitution and Child Pornography. Optional protocols There are three optional protocols to the Convention on the Rights of the Child. The first, the Optional Protocol on the Involvement of Children in Armed Conflict requires parties to ensure that children under the age of 18 are not recruited compulsorily into their armed forces and calls on governments to do everything feasible to ensure that members of their armed forces who are under 18 years do not take part in hostilities. This protocol entered into force on 12 July 2002. As of , 172 states are party to the protocol, and another 8 states have signed but not ratified it. The second, the Optional Protocol on the Sale of