(with no guarantee that this application or any future such application, will be granted). Individual states are also permitted to opt out of the law or modify its provisions as they see fit such as by imposing a temporary rather than a lifetime ban or limiting the ban to certain offenses. Challenges to the policy In January 2001, the Ninth Circuit Court of Appeals declared the law to be unconstitutional in cases where the criminal wrongdoing in question was actually committed not by the tenant but by a person not legally residing in the unit, such as the tenant's grown child or guest. Rucker v. Davis concerned a 63-year-old grandmother, Pearlie Rucker, who was evicted because a member of her family had incurred a drug conviction. The court held that the federal statute that allowed the Oakland Housing Authority to evict Rucker should not be interpreted to allow the eviction of a tenant merely because of the wrongdoing of another. However, the Ninth Circuit's en banc ruling was overturned in 2002 by the United States Supreme Court in HUD v. Rucker. Chief Justice William Rehnquist, writing for a unanimous Court (with Justice Stephen Breyer having recused himself), held that "the plain language of [the statute] requires leases that grant public housing authorities the discretion to terminate tenancy without regard to the tenant’s knowledge of the drug-related criminal activity." Criticisms The law has encountered fierce opposition from African-American groups, and advocates for the poor in general. Some critics have argued that because evictions are civil proceedings and not criminal, less evidence is needed to prove a case against a tenant. Additionally, opponents have pointed out the aspect of the policy that allows housing authorities to evict tenants based on the actions of their relatives and guests. Between 2003 and 2007, Representative Barbara Lee of California, attempted to amend One Strike You're Out with legislation intended to address this common criticism. H.R. 1309, H.R. 173 and H.R 1429 would exempt elderly tenants and those who were not aware of such criminal activity, from being evicted or denied admissions into a housing project. All three bills died in committee. Other applications Since the passage of the public-housing law that forms the basis for this article, the term "One strike, you're out" has also acquired other popular applications, including the idea that the Roman Catholic Church should defrock priests upon the first sustained allegation