persecution of Falun Gong includes a multifaceted propaganda campaign, a program of enforced ideological conversion and re-education, as well as a variety of extralegal coercive measures, such as arbitrary arrests, forced labour, and physical torture, sometimes resulting in death. Russia In 2008 the Russian Interior Ministry prepared a list of "extremist groups". At the top of the list were Islamic groups outside of "traditional Islam", which is supervised by the Russian government. Next listed were "Pagan cults". In 2009 the Russian Ministry of Justice created a council which it named the "Council of Experts Conducting State Religious Studies Expert Analysis." The new council listed 80 large sects which it considered potentially dangerous to Russian society, and it also mentioned that there were thousands of smaller ones. The large sects which were listed included: The Church of Jesus Christ of Latter-day Saints, the Jehovah's Witnesses, and other sects which were loosely referred to as "neo-Pentecostals". United States In the 1970s, the scientific status of the "brainwashing theory" became a central topic in U.S. court cases where the theory was used to try to justify the use of the forceful deprogramming of cult members. Meanwhile, sociologists who were critical of these theories assisted advocates of religious freedom in defending the legitimacy of new religious movements in court. In the United States the religious activities of cults are protected under the First Amendment of the United States Constitution, which prohibits governmental establishment of religion and protects freedom of religion, freedom of speech, freedom of the press, and freedom of assembly. However, no members of religious groups or cults are granted any special immunity from criminal prosecution. In 1990, the court case of United States v. Fishman (1990) ended the usage of brainwashing theories by expert witnesses such as Margaret Singer and Richard Ofshe. In the case's ruling, the court cited the Frye standard, which states that the scientific theory which is utilized by expert witnesses must be generally accepted in their respective fields. The court deemed brainwashing to be inadmissible in expert testimonies, using supporting documents which were published by the APA Task Force on Deceptive and Indirect Methods of Persuasion and Control, literature from previous court cases in which brainwashing theories were used, and expert testimonies which were delivered by scholars such as Dick Anthony. Western Europe The governments of France and Belgium have taken policy positions which accept "brainwashing" theories uncritically,