The non-Orthodox movements settled this decades ago: Reform ordained Sally Priesand in 1972, the Reconstructionists Sandy Eisenberg Sasso in 1974, and the Conservative movement Amy Eilberg in 1985 after a long and bitter fight that produced a breakaway seminary. Orthodoxy has not, and the argument there is about function rather than capacity — nobody now claims women cannot learn the material, since women's advanced Talmud study is established in Modern Orthodox institutions in New York and Jerusalem, and yoatzot halacha, women who advise on the laws of niddah, are widely accepted. The contested questions are whether a woman may hold a communal office, lead parts of a service requiring a quorum she is not counted in, and carry the title. Yeshivat Maharat, founded by Sara Hurwitz and Avi Weiss in 2009, has ordained around a hundred women, most using maharat or rabbanit rather than rabbi; the Rabbinical Council of America resolved in 2015 that it will not ordain or recognise women rabbis under any title, and the Agudath Israel position is harder still. Partnership minyanim, which divide the service so women lead the parts that do not require a quorum, operate in Jerusalem, Tel Aviv, New York and London and are not recognised as Orthodox by the Israeli rabbinate. The related fight over the mechitza — how high, how opaque, and whether the women's section can be beside rather than behind — is the same argument conducted in plywood.