During the same time, the City and County of San Francisco passed two resolutions. Resolution No. 234-99 "calls for the Religious Right to take accountability for the impact of their long-standing rhetoric denouncing gays and lesbians, which leads to a climate of mistrust and discrimination that can open the door to horrible crimes such as those committed against Mr. Gaither" and Resolution No. 873-98 was specifically directed at "anti-gay" television advertisements. AFA unsuccessfully challenged these actions as violating the Free Speech and Free Exercise clauses of the First Amendment in "American Family Association v. City and County of San Francisco".