In the past, the term lay brother was used within some Catholic religious institutes, to distinguish members who were not ordained from those members who were clerics (priests and seminarians). This term is now considered controversial by some because of the history of inequality between Brothers and clerics. The term "lay" has also been used in the past to designate someone as "uneducated" in contrast to "illiterate." Instead, the term "religious Brother" or simply "Brother" is appropriate when referring to a vowed male religious who is neither priest, deacon, nor seminarian. The vocational title "Brother" is generally capitalized in order to distinguish it from the generic use of the biologically relational term "brother."