often termed "coming out of the broom-closet". Wiccans have also experienced difficulties in administering and receiving prison ministry, although not in the UK of recent times. In 1985, as a result of Dettmer v. Landon [617 F. Supp. 592 (D.C. Va 1985)], the District Court of Virginia ruled that Wicca is a legally recognised religion and is afforded all the benefits accorded to it by law. This was affirmed a year later by Judge John D. Butzner, Jr. of the United States Court of Appeals for the Fourth Circuit [Dettmer v. Landon, 799 F. 2d 929 (4th Cir. 1986)]. Nevertheless, Wiccans are sometimes still stigmatised in America, and many remain secretive about their beliefs. Also in 1985, conservative legislators in the United States introduced three pieces of legislation designed to take away the tax-exempt status of Wiccans. The first one was House Resolution (H.R.) 3389, introduced on September 19, 1985, by Congressman Robert S. Walker (R-Pennsylvania), which would have amended to the United States Internal Revenue Code that any organisation which promotes witchcraft would not be exempt from taxation. On the other side of Congress, Senator Jesse Helms (R-North Carolina) added Amendment 705 to H.R. 3036, "The Treasury, Postal, and General Government Appropriations Bill for 1986", which similarly stated that organisations promoting witchcraft would not be eligible for tax-exempt status. After being ignored for a time, it was attached to H.R. 3036 by a unanimous voice vote of the senators. Congressman Richard T. Schulze (R-Pennsylvania) introduced substantially the same amendment to the Tax Reform Bill of 1985. When the budget subcommittee met on October 30, the Helms Amendment was thrown out as it was not considered germane to the bill. Following this, Schulze withdrew his amendment from the Tax Reform Bill, leaving only H.R. 3389, the Walker Bill. Joe Barton (R-Texas) was attracted to become a co-sponsor of this bill on November 14, 1985. The Ways and Means Committee set aside the bill and quietly ignored it, and the bill was allowed to die with the close of the 99th session of Congress in December 1986. In 2002, Cynthia Simpson of Chesterfield County, Virginia, submitted an application to be invited to lead prayer at the local Board of Supervisors meetings, but in a response was told that because the views of Wicca were not "consistent with the Judeo-Christian tradition", her application had been denied. After the Board reviewed and affirmed