Attempts to decriminalize cannabis in the United States began in the 1970s. Several jurisdictions have subsequently decriminalized cannabis (also referred to as marijuana or marihuana) for non-medical purposes, as views on cannabis have liberalized, peaking in 1978. The decriminalization movement supports efforts ranging from reducing penalties for cannabis-related offenses to removing all penalties related to cannabis, including sale and cultivation. Proponents of cannabis decriminalization argue that a substantial amount of law-enforcement resources would be freed, which could be used to prevent more serious crimes, and would reduce income earned by street gangs and organized crime who sell or traffic cannabis. Opponents argue that cannabis on street level today has a much higher percent of THC with a stronger drug effect, the decriminalization will lead to increased crime, increased cannabis usage, and subsequent abuse of other illicit drugs. Gonzales v. Raich, 2005 ruled in a 6-3 decision that the Commerce Clause of the United States Constitution allowed the federal government to ban the use of cannabis, including medical use.