of Grey of Codnor was treated as an exception to this principle, as a claim to it had been submitted prior to these recommendations being made to the Sovereign. Titles in the Peerage of Scotland cannot go into abeyance, because in Scottish law the eldest sister is preferred over younger sisters; sisters are not considered equal co-heirs. It is common, but incorrect, to speak of peerage dignities which are dormant (i.e. unclaimed) as being in abeyance. Peerages called out of abeyance by year of initial abeyance Settling litigation Abeyance can be used in cases where parties are interested in temporarily settling litigation while still holding the right to seek relief later if necessary. This may be considered a desirable outcome in cases where the party to the lawsuit is an organization with a transient membership and political perspective. The use of abeyance in such instances can allow such an organization to 'settle' with the party without officially binding its actions in the future, should a new group of decision makers within the organization choose to pursue taking the dispute to court. For example, abeyance was used as a settlement method in a Canadian lawsuit involving the University of Victoria Students' Society (UVSS), the BCCLA, and a campus anti-abortion club to whom the UVSS denied funding. The parties agreed to settle the lawsuit by holding the case in abeyance in return for the UVSS temporarily giving resources back to the club. With this arrangement, the anti-abortion club held on to its right to immediately reopen the case again should the UVSS deny resources to the club in the future, and the UVSS was able to avoid an expensive legal battle it did not have the will to pursue at the time. Thus the use of abeyance provided the security of a settlement for the anti-abortion campus club, while preserving the student society's voting membership's ability to take the matter back to court should they choose in the future to deny resources to the club. Other court cases may be held in abeyance when the issue may be resolved by another court or another event. This saves time and effort trying to resolve a dispute that may be made moot by the other events. During lawsuits related to the Patient Protection and Affordable Care Act after the Supreme Court of the United States granted certiorari in King v. Burwell, attorneys in Halbig