used in support of legislative and legal efforts to prolong the life of a woman in an persistent vegetative state. It has also been used to promote providing inexpensive medical care for people in impoverished countries. Following the Boston Marathon bombing, the Catholic bishops of Massachusetts opposed the death penalty for terrorist bomber Dzhokhar Tsarnaev, citing the need to build a culture of life. In their statement, they cited a 2005 document by the United States Conference of Catholic Bishops, A Culture of Life and the Penalty of Death, which said "no matter how heinous the crime, if society can protect itself without ending a human life, it should do so." A growing culture of life in the United States, one that took the protection of life more seriously, led to the rapid adoption of infant safe-haven laws in the early 2000s. Under these laws, mothers can leave their newborn children in places such as hospitals, police stations and fire stations, without being criminally charged with child abandonment. Culture of death Pope John Paul II also used the opposing term "culture of death" in Evangelium vitae (April 1995): He argued that there was "a war of the powerful against the weak: a life which would require greater acceptance, love and care is considered useless, or held to be an intolerable burden, and is therefore rejected in one way or another." Those who are ill, handicapped, or just simply threaten the well being or lifestyle of the more powerful thus become enemies to be eliminated. John Paul said he saw this as applying both between individuals and between peoples and states. He added his belief that every time an "innocent life" is taken (dating back to the time of Cain and Abel) that it was "a violation of the ‘spiritual’ kinship uniting mankind in one great family, in which all share the same fundamental good: equal personal dignity." Any threat to the human person, including wars, class conflict, civil unrest, ecological recklessness, and sexual irresponsibility, should therefore be regarded in his opinion as part of the "culture of death." Without morals, Cardinal Cormac Murphy-O'Connor said, "it is the strong who decide the fate of the weak," and "human beings therefore become instruments of other human beings... We are already on that road: for what else is the termination of millions of lives in the womb since the Abortion Act was introduced,