divorce laws, the refusal to engage in sexual intercourse with one's spouse may give rise to a grounds for divorce, which may be listed under "grounds of abandonment". Concerning no-fault divorce jurisdictions, author James G. Dwyer stated that no-fault divorce laws "have made it much easier for a woman to exit a marital relationship, and wives have obtained greater control over their bodies while in a marriage" because of legislative and judicial changes regarding the concept of a marital exemption when a man rapes his wife. There are various legal positions regarding the meaning and legality of sexual intercourse between persons of the same sex or gender. For example, in the 2003 New Hampshire Supreme Court case Blanchflower v. Blanchflower, it was held that female same-sex sexual relations, and same-sex sexual practices in general, did not constitute sexual intercourse, based on a 1961 entry in Webster's Third New International Dictionary that categorizes sexual intercourse as coitus; and thereby an accused wife in a divorce case was found not guilty of adultery. Some countries consider same-sex sexual behavior an offense punishable by imprisonment or execution; this is the case, for example, in Islamic countries, including LGBT issues in Iran. Opposition to same-sex marriage is largely based on the belief that sexual intercourse and sexual orientation should be of a heterosexual nature. The recognition of such marriages is a civil rights, political, social, moral and religious issue in many nations, and the conflicts arise over whether same-sex couples should be allowed to enter into marriage, be required to use a different status (such as a civil union, which either grant equal rights as marriage or limited rights in comparison to marriage), or not have any such rights. A related issue is whether the word marriage should be applied. Religious views There are wide differences in religious views with regard to sexual intercourse in or outside of marriage: Most denominations of Christianity, including Catholicism, have strict views or rules on what sexual practices are and are not acceptable. Most Christian views on sexual intercourse are influenced by various interpretations of the Bible. Sexual intercourse outside of marriage, for example, is considered a sin in some churches; in such cases, sexual intercourse may be called a sacred covenant, holy, or a holy sacrament between husband and wife. Historically, Christian teachings often promoted celibacy, although today usually only certain members (for example, certain religious leaders)