and pre-Christian Roman Empire, homosexual behavior had been acceptable as long as the adult male citizen took the penetrative role with a passive partner of lower social status. Laws regulating homosexuality were directed primarily at protecting underage male citizens. Those who committed a sex crime (stuprum) against a freeborn male minor were penalized by death or a fine, depending on the circumstances. Letters written to Cicero suggest that the law was used primarily to harass political opponents, and may have been applied also to citizens who willingly took the passive role in sex acts (see Sexuality in ancient Rome and Lex Scantinia). Leviticus 18 and 20 These chapters of Leviticus form part of the Holiness code. Leviticus 18:22 says: and Leviticus 20:13 states: It is widely argued that the things condemned in these chapters are "deemed wrong not simply because pagan Canaanites indulged in them, but because God has pronounced them wrong as such." (Hilborn 2002, p. 4; cf. Issues in human sexuality, para. 2.11; Amsel). This was also the interpretation taken in the rabbinic interpretations in the Mishnah and Talmud, which also extended this to include female homosexual relations, although there are no explicit references in the Hebrew Bible to this. Various counter-arguments have been suggested: Loren L. Johns writes that these texts were purity codes to keep Israel separate from the Canaanites and that as Jesus rejected the whole purity code they are no longer relevant. Mona West argues that "These verses in no way prohibit, nor do they even speak, to loving, caring sexual relationships between people of the same gender", speculating that these laws were to prevent sexual abuse. Other Christian theologians hold that the New Testament classifies ceremonial and dietary laws as typological in nature and fulfilled in Christ (; ; ), and thus abrogated as to their religious observance "according to the letter," while the moral law is seen as upheld. (; ) Such theologians have said that this abrogation does not extend to homosexuality, which remains in their interpretation as one of the few sins unconditionally condemned. They believe there is no evident provision of marriage being given in the Bible to sanctify it. Books of Samuel: David and Jonathan The account of the friendship between David and Jonathan was recorded favourably in the Books of Samuel (1 Samuel 18; 20; 2 Samuel 1) and although most scholars have always interpreted it as