In January 1879, when Smith was two years old, the U.S. Supreme Court in "Reynolds v. United States" upheld the constitutionality of the Morrill Anti-Bigamy Act of 1862, which had criminalized the Latter-day Saint practice of plural marriage. Due to aggressive federal enforcement of this ruling, as well as the Edmunds Act of 1882 and the Edmunds-Tucker Act of 1887, many LDS Church leaders, including Smith's father, were either imprisoned or forced into hiding and exile during most of the 1880s. Smith's father, as the keeper of the records of the Endowment House, felt a special need to avoid capture since the records could allow the federal authorities to easily prove polygamy charges against certain Latter-day Saint men. In January 1885, Smith's parents and his younger sister, Julina, left for the Sandwich Islands (modern Hawaii), where Smith's father had served a mission as a teenager in the 1850s. In their absence, Smith continued to live in the family home with his brothers and sisters and his father's other wives, whom he "lovingly called 'aunties'". Smith's mother returned to Salt Lake City in 1887, followed later by his father. Even after his return, Joseph F. Smith was unable to openly visit and care for his wives and children until receiving a presidential pardon from U.S. President Benjamin Harrison in September 1891.