 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."