Jesus Christ Christian, a Wiccan witch and a Satanist) protesting denial of access to ceremonial items and opportunities for group worship was brought before the Supreme Court. Among the denied objects was instructions for runic writing requested by an Ásatrúarmaður, which was initially denied when prison officials raised concerns that runic writing could be used for coded gang communication. In an interview about the role of race-based gangs and other extremists in America's prisons, the historian Mark Pitcavage came to the conclusion that "[n]on-racist versions of Ásatrú and Odinism are pretty much acceptable religions in the prisons", but materials from racist variants of these religions may be prohibited by corrections departments. In early 2011, a Stillwater prisoner named Stephen Hodgson filed a federal lawsuit against the state of Minnesota claiming his religious rights have been violated. Hodgson claimed he was prohibited from practising his Wiccan faith when guards and prison administrators refused to allow him to use prayer oils and herbs needed. He also claimed that his religious mail had been confiscated and that he had been prohibited from burning incense or using prayer oils and herbs. He claimed those items were necessary for the practice of his religion and that they posed no danger to guards or other inmates. The Minnesota Department of Human Rights agreed with Hodgson, saying "probable cause exists to believe that an unfair discriminatory practice was committed." The discrimination case is awaiting trial. Wicca According to Gerald Gardner, who popularised Wicca in the twentieth century, the religion is a survival of a European witch-cult that was persecuted during the witch trials (sometimes called the Burning Times), and the strong element of secrecy that traditionally surrounds the religion was adopted as a reaction to that persecution. Since then, Margaret Murray's theory of an organised pan-European witch-cult has been discredited, and doubts raised about the age of Wicca; many Wiccans no longer claim this historical lineage. However, it is still common for Wiccans to feel solidarity with the victims of the witch trials and, being witches, to consider the witch-craze to have been a persecution against their faith. There has been confusion that Wicca is a form of Satanism, despite important differences between these religions. Due to negative connotations associated with witchcraft, many Wiccans continue the traditional practice of secrecy, concealing their faith for fear of persecution. Revealing oneself as Wiccan to family, friends, or colleagues is