However, the law still technically remained in force in the rest of New York state until it was repealed in 2010. This caused some people in New York state to be charged under that section of the law after "Loper", but before it was repealed. Civil liberties groups have campaigned against the more targeted aggressive begging laws, however, they have been found to comply with the First Amendment. In 2006, the City of Rochester's current aggressive begging laws withstood a legal challenge in "People v. Barton". And in 2010, New York City's current aggressive begging laws also withstood challenge in "People v. Stroman". In June 2012, Governor Lincoln Chafee of Rhode Island signed a bill into law that gives homeless people in that state some clearer rights than before. The act of 'aggressive panhandling' has only recently become criminalized in Tennessee; becoming official in 2015. In recent years, there has been an apparent push for the need to implement anti-panhandling laws across America. It is believed that this is a result of adverse effects of the Great Recession, particularly foreclosure. Under the Tennessee Code (§ 39-17-313), the act of 'aggressive panhandling' is classified as a criminal offence punishable by a fine and/or jail. Per the Code, 'aggressive panhandling' is committed if an individual, while requesting money or donations: The severity of the punishment greatly depends on whether an individual has previously violated the Code. A first offence (classified as a Class C misdemeanour) could result in a maximum fine of $50 and/or up to 30 days in jail. A second offence (classified as a Class B misdemeanour) could increase this penalty to a maximum fine of $500 and/or up to 6 months in jail. While the Tennessee Code is written in very broad and general terms, several city ordinances, most of which were enacted before the Tennessee Code, provide specific restraints on the actions of panhandlers. The Memphis Code of Ordinances contains a very lengthy and detailed section (§ 6-56) on panhandling. Under this section, panhandling is prohibited within a specified zone of Downtown Memphis and is generally prohibited between the hours of 7pm and 8am. Similar to the Nashville ordinance, the Memphis ordinance also expressly states areas where panhandling is prohibited including, but not limited to, within 25-feet of any religious assembly, within 50-feet of any entrance or exit from a bank/ATM machine and in any public transportation vehicle.