Yet further evidence that NARAL’s ideology makes it confuse violence and non-violence: Another amicus brief in Bray was submitted by 17 individuals such as Daniel Berrigan “who have been or are actively involved in the civil rights, anti-poverty, labor and peace movements” and who “share a common belief in the importance of nonviolent resistance to injustice.” That amicus brief, like Roberts’s submitted on behalf of the United States, sided with the position of the anti-abortion protesters that the Ku Klux Klan Act of 1871 did not properly apply to their unlawful acts of trespass and obstruction.