Families of converts to NRMs have attempted to invoke brainwashing theories to satisfy conservatorship statutory guidelines. Conservatorship is a legal concept in the United States that grants a responsible person custody over another adult who cannot care for herself or himself, either financially and/or in daily life, due to physical and/or mental limitations. Typically, conservatorship cases involved the elderly, mainly those suffering from dementia-related illnesses. However, conservatorship cases involving younger adults and their participation in new religious movements increased during the mid-1970s, with many of those U.S. judges granting temporary conservatorships. The use of brainwashing theories in conservatorship cases was deemed inadmissible as a result of the Katz v. Superior Court (1977) ruling. The ruling implied that the statutory guideline for conservatorships only referred to "needs of health, food, clothing, and shelter" and that investigating if conversion is "induced by faith or by coercive persuasion is ... not in turn investigating and questioning the validity of that faith." In 2016, Israeli anthropologist of religion and fellow at the Van Leer Jerusalem Institute Adam Klin-Oron said about then-proposed "anti-cult" legislation: