disobedience occurs when a citizen disobeys laws to lay claim to some right denied to them, as when Black people illegally protested during the civil rights movement. "Policy-based" civil disobedience occurs when a person breaks the law to change a policy they believe is dangerously wrong. Some theories of civil disobedience hold that civil disobedience is only justified against governmental entities. Brownlee argues that disobedience in opposition to the decisions of non-governmental agencies such as trade unions, banks, and private universities can be justified if it reflects "a larger challenge to the legal system that permits those decisions to be taken". The same principle, she argues, applies to breaches of law in protest against international organizations and foreign governments. It is usually recognized that lawbreaking, if it is not done publicly, at least must be publicly announced to constitute civil disobedience. But Stephen Eilmann argues that if it is necessary to disobey rules that conflict with morality, we might ask why disobedience should take the form of public civil disobedience rather than simply covert lawbreaking. If a lawyer wishes to help a client overcome legal obstacles to securing their natural rights, he might, for instance, find that assisting in fabricating evidence or committing perjury is more effective than open disobedience. This assumes that common morality does not have a prohibition on deceit in such situations. The Fully Informed Jury Association's publication "A Primer for Prospective Jurors" notes, "Think of the dilemma faced by German citizens when Hitler's secret police demanded to know if they were hiding a Jew in their house." By this definition, civil disobedience could be traced back to the Book of Exodus, where Shiphrah and Puah refused a direct order of Pharaoh but misrepresented how they did it. (Exodus 1: 15–19) Violent vs. nonviolent There have been debates as to whether civil disobedience must necessarily be non-violent. Black's Law Dictionary includes nonviolence in its definition of civil disobedience. Christian Bay's encyclopedia article states that civil disobedience requires "carefully chosen and legitimate means", but holds that they do not have to be non-violent. It has been argued that, while both civil disobedience and civil rebellion are justified by appeal to constitutional defects, rebellion is much more destructive; therefore, the defects justifying rebellion must be much more serious than those justifying disobedience, and if one cannot justify civil rebellion, then one cannot justify a civil disobedient's use of force