Mormonism Early in its history, The Church of Jesus Christ of Latter-day Saints practiced polygamy in the United States and referred to it as "plural marriage". As early as 1831, Joseph Smith Jr., the founder and father of the Church, would claim to have received a revelation on Celestial marriage although it was not recorded until 1843 and remained a secret practice until 1852. The public revelation of the Church's practice of polygamy led to persecution. Many novelists began to write books and pamphlets condemning polygamy, portraying it as a legalized form of slavery. The outcry against polygamy eventually led to the federal government's involvement and the enacting of anti-polygamy laws. (The U.S. Congress made the practice illegal in U.S. Territories in 1862). Many members of the Church were sent to Canada and Mexico to set up communities free from prosecution; for example, Cyril Ogston founded Seven Persons, Alberta. Although Latter-day Saints believed that their religiously-based practice of plural marriage was protected by the United States Constitution, the U.S. Supreme Court had already specifically held in 1878 that LDS polygamy was not protected by the Constitution, in the case of Reynolds v. U.S., 98 U.S. 145 (1878), under the longstanding legal principle that "Laws are made for the government of actions, and while they cannot interfere with mere religious belief and opinions, they may with practices." (Id. at 166.) [21] Opponents used polygamy to delay Utah statehood until 1896. Increasingly harsh anti-polygamy legislation penalized Church members, disincorporated the Church, and permitted the seizure of Church property until the Church ordered the discontinuance of the practice in 1890. National attention in the United States again focused on potential polygamy among the Church in the early 20th century during the House hearings on Representative-elect B. H. Roberts and Senate hearings on Senator-elect Reed Smoot (the Smoot Hearings). This caused Church president Joseph F. Smith to issue his Second Manifesto against polygamy in 1904. This manifesto clarified that all members of the LDS Church were prohibited from performing or entering into polygamous marriages, no matter what the legal status of such unions was in their respective countries of residence. Despite this, it is documented that many Mormon leaders continued to secretly practice post-manifesto polygamy for many years, because the ban on new plural marriage did not nullify existing marriages. Eventually, those involved in such marriages died, but many Latter-day Saints today can remember grandparents and even parents who had married more than one wife during the period prior to the Manifesto. Since that time, it has been Church policy to excommunicate any member either practicing or openly advocating the practice of polygamy. It was considered a divine revelation from God to discontinue the practice, and Joseph F. Smith was considered to be the spokesman (prophet) of God according to the Mormon faith. Although most Mormons accepted the ban on plural marriage, various splinter groups left the Church to continue the practice of polygamy. Polygamy among these groups persists today in Utah, neighboring states, and the spin-off colonies, as well as among isolated individuals with no organized church affiliation. Polygamist churches of Mormon origin are called Mormon fundamentalist. The Salt Lake Tribune states there are as many as 37,000 Mormon fundamentalists, with less than half of them living in polygamous households. Most of the polygamy is believed to be restricted to about a dozen extended groups of polygamous Mormon fundamentalists. The Church of Jesus Christ of Latter-day Saints believes that it is improper to call any of these splinter polygamous groups "Mormon." LDS.org, the official site of the LDS church states: "The term Mormon is not properly applied to the other ... churches that resulted from the split..." The practice of informal polygamy among these groups presents itself with interesting legal issues. It has been considered difficult to prosecute polygamists partly because they are not formally married under state laws. Without evidence that suspected offenders have multiple formal or common-law marriages, these groups are merely subject to the laws against adultery or unlawful cohabitation. These laws are not commonly enforced because they also criminalize other behavior that is otherwise socially sanctioned. However, some "Fundamentalist" polygamists marry women prior to the age of consent or commit fraud to obtain welfare and other public assistance. In 2005, the state attorneys-general of Utah and Arizona issued a primer on helping victims of domestic violence and child abuse in polygamous communities. Enforcement of other crimes such as child abuse, domestic violence, and fraud were emphasized over the enforcement of anti-polygamy laws.