All four would later reverse their positions. The discovery doctrine has been condemned as socially unjust, racist, and in violation of basic and fundamental human rights. The United Nations Permanent Forum on Indigenous Issues (UNPFII) noted the doctrine of discovery "as the foundation of the violation of their (Indigenous people) human rights". The eleventh session of the UNPFII, held at the UN's New York headquarters from 7–18 May 2012, had the special theme of "The Doctrine of Discovery: its enduring impact on Indigenous peoples and the right to redress for past conquests (articles 28 and 37 of the United Nations Declaration on the Rights of Indigenous Peoples)". It called for a mechanism to investigate historical land claims, with speakers observing that "The Doctrine of Discovery had been used for centuries to expropriate Indigenous lands and facilitate their transfer to colonizing or dominating nations". The General Convention of the US Episcopal Church, conducted on 8–17 August 2009, passed a resolution officially repudiating the discovery doctrine. At the 2012 Unitarian Universalist Association General Assembly in Phoenix, Arizona, delegates passed a resolution repudiating the doctrine of discovery and calling on Unitarian Universalists to study the doctrine and eliminate its presence from the current-day policies, programs, theologies, and structures of Unitarian Universalism. In 2013, at its 29th General Synod, the United Church of Christ repudiated the doctrine in a near-unanimous vote. In 2014, Ruth Hopkins, a tribal attorney and former judge, wrote to Pope Francis asking him to formally revoke the papal bull of 1493. At the 2016 Synod, 10–17 June in Grand Rapids, Michigan, delegates to the annual general assembly of the Christian Reformed Church rejected the doctrine of discovery as heresy in response to a study report on the topic. At the 222nd General Assembly of the Presbyterian Church (U.S.A.) (2016), commissioners called on members of the church to repudiate the doctrine of discovery. The commissioners directed that a report be written reviewing the history of the doctrine. That report was approved by the 223rd General Assembly (2018), along with recommendations for a variety of additional actions that could be taken by the church at all levels to acknowledge indigenous peoples and to confront racism against them. In 2016, the Churchwide Assembly of the Evangelical Lutheran Church in America (ELCA), adopted Assembly Action CA16.02.04 titled "Repudiation of the Doctrine of Discovery" by a vote of 912–28, describing the doctrine as "an example