were outspoken critics have included John Boehner, David Vitter, Paul Ryan, Newt Gingrich, Rick Santorum, Bobby Jindal, Jeb Bush, Bob McDonnell, Marco Rubio, Michael Steele, Donald Carcieri and Sam Brownback. Catholics Rudolph Giuliani, Chris Christie, Tim Kaine, James Martin, Cardinal Joseph W. Tobin, Archbishop Vincenzo Paglia, Cardinal Blase Cupich, Patrick J. Conroy (Jesuit chaplain to the U. S. House of Representatives), and Bob Casey Jr. have supported gay rights and civil unions but not same-sex marriage. Liberal Catholics have generally supported repeal of sodomy laws that called for jail time for homosexuals and Employment Non-Discrimination laws that would prohibit large employers from firing workers because of sexual orientation. Conservative Catholics have taken the contrary view, rejecting claims that these are examples of "unjust discrimination" and that because homosexual act is an intrinsic evil, it must always be opposed. Abortion In accordance with its teachings, the Catholic Church opposes abortion in all circumstances and often leads the national debate on abortion. The Roman Catholic Church has been a fierce opponent of liberalized abortion laws and has organized political resistance to such legislation in several Western countries. Before the Roe v. Wade decision making abortion legal in the United States, the anti-abortion movement in the United States consisted of elite lawyers, politicians, and doctors, almost all of whom were Catholic. The only coordinated opposition to abortion during the early 1970s came from the United States Conference of Catholic Bishops and the Family Life Bureau, also a Catholic organization. Mobilization of a wide-scale anti-abortion movement among Catholics began quickly after the Roe v. Wade decision with the creation of the National Right to Life Committee (NRLC). The NRLC also organized non-Catholics, eventually becoming the largest anti-abortion organization in the United States. The anti-abortion wing of the Democratic Party was also led by Catholic Robert P. Casey, Sr. other anti-abortion Democrats including, Sargent Shriver, Raymond Flynn and Bob Casey Jr. Reception of communion by Catholic politicians who support abortion rights is controversial in the United States. Such cases typically involve a bishop who prepares to withhold communion from a Catholic politician, though in some cases excommunication has been suggested, and in others, a bishop has instructed a politician to refrain from receiving communion. The first such case was that of Lucy Killea, though such incidents have subsequently occurred during national elections. In 2004, Cardinal Joseph Ratzinger, then-prefect of the Congregation for the Doctrine of