efforts. "Continuing Congregationalism" However, a small but vocal minority of ministers and laymen protested the developments, charging that any merger with a confessional, presbyterial body such as the E&R Church would destroy the heritage and structure of American Congregationalism. These opponents formed groups that published pamphlets and attempted to persuade churches to reject the proposed merger. An anti-merger congregation in Brooklyn filed suit against the CC moderator, Helen Kenyon, in 1949 to legally stop the merger proceedings; the major legal contention made by the church and the anti-union advocates was that the CC General Council possessed no authority to enter into a merger as a national entity. After some initial victories in lower courts, a New York state Court of Appeals declined jurisdiction and judged in favor of Ms. Kenyon and the CC Churches in 1953. With this defeat, the anti-merger forces turned instead toward forming a new denomination, which became the National Association of Congregational Christian Churches, founded in 1955; a preponderance of these churches were located in non-metropolitan New England, southeastern Michigan, parts of Wisconsin and Illinois, and southern California. Some years before that, motivated by different concerns, chiefly doctrine, a group of evangelical-leaning congregations formed the Conservative Congregational Christian Conference, in 1948. Union approved The final vote on participation by the General Council of Congregational Christian Churches in the UCC merger took place at the 1956 General Council, meeting in Omaha, Nebraska. Eighty-eight (88) percent of the delegates approved the motion to unite with the Evangelical and Reformed Church, and the latter body's General Synod approved by an even wider margin. This set the stage for the Uniting General Synod, which took place in Cleveland, Ohio, on June 25, 1957; the General Council of Congregationalism Christian Churches were represented by the Rev. Fred Hoskins, who had succeeded Horton some years earlier as general minister and president. Hoskins would become, along with E&R President James Wagner, one of the co-presidents of the UCC. The actual consummation of the UCC, however, did not occur until 1961, when a sufficient number of CC congregations voted to approve the denomination's new constitution. The CC Churches brought into the new UCC approximately 1.4 million members, about 60 percent of the total number of members in the new denomination. In order to attend to necessary legal business continuing from years past, the General Council remained incorporated until 1984, when it finally dissolved. See