the Faith (who would later become Pope Benedict XVI), instructed American bishops in a confidential memorandum that communion must be denied to Catholic politicians who support legal abortion. However, Cardinals O'Malley, Egan, McCarrick, Wuerl, Mahony and George have said they would not deny communion to a person in public life who supports abortion rights. Cardinal Burke and Charles Chaput, Archbishop of Philadelphia, have shown support for Ratzinger's position, but , neither has followed through on this. During the 2004 presidential campaign, four bishops planned to deny communion to Catholic politicians who had voted for John Kerry. This provoked a negative reaction, and the Catholic Church took a different approach for the 2008 election. The new message was compiled into a brochure titled "Forming Consciences for Faithful Citizenship," which "emphasized that issues involving 'intrinsically evil' actions could not be equated morally with others," according to the Times. The brochure cites abortion as the "prime example," and it also mentions euthanasia, torture, genocide, unjust war and racism. In the 2008 U.S. presidential campaign, as many as 89 Catholic bishops proclaimed that Catholics should make abortion their defining issue in the election. In November 2009, Rhode Island Rep. Patrick Kennedy disclosed that Thomas Tobin had ordered priests in the diocese to deny him communion because of Kennedy's position in favor of unrestricted abortion. Michael Humphrey of the National Catholic Reporter viewed the 54-45% majority of Catholic voters choosing Obama in the 2008 presidential election as a repudiation of bishops who had warned that voting for Obama would constitute grave matter. The University of Notre Dame, a Catholic institution, named President Barack Obama commencement speaker at its 2009 graduation and bestowed an honorary doctorate degree on him. The invitation drew criticism from Catholics and some members of the church hierarchy because of Obama's policies in favor of promoting and funding abortion. Polling results show that a majority of Catholics classify themselves as anti-abortion; a 2009 poll showed a 52% majority identifying as anti-abortion. Pew Research, combining polls from 2011 and 2013, notes that over half (53%) of white Catholics believe abortion should be legal in all or most cases, with 41% saying it should be illegal in all or most cases. Among Hispanic Catholics, 43% say it should be legal in all or most cases, while 52% say it should be illegal in all or most cases. Birth control In 1948, Archbishop Richard Cushing