his title as Reich's Bishop legislative power for all Protestant church bodies in Germany, issued the so-called muzzle decree, which forbade any debate about the struggle of the churches within the rooms, bodies and media of the church. The Emergency Covenant of Pastors answered this decree by a declaration read by opposing pastors from their pulpits on 7 and 14 January. Müller then prompted the arrestment or disciplinary procedures against about 60 pastors alone in Berlin, who had been denounced by spies or congregants of German Christian affiliation. The Gestapo tapped Niemöller's phone and thus learned about his and Walter Künneth's plan to personally plea Hitler for a dismissal of Ludwig Müller. The Gestapo – playing divide et impera – publicised their intention as a conspiracy and so the Lutheran church leaders Marahrens, Meiser, and Wurm distanced themselves from Niemöller on 26 January. The same day Ludwig Müller decreed the Führerprinzip, a hierarchy of subordination to command, within the Evangelical Church of the old-Prussian Union. Thus having usurped the power the German Christian Müller forbade his unwelcome competitor as church leader, the German Christian Werner, to discharge his duties as praeses of the Church Senate and president of the Evangelical Supreme Church Council. Werner then sued Müller at the Landgericht I in Berlin. The verdict would have major consequences for the Evangelical Church of the old-Prussian Union. Also opponents, legally consulted by Judge Günther (judge at the Landgericht court), Horst Holstein, Friedrich Justus Perels, and Friedrich Weißler, covered Ludwig Müller and his willing subordinates with a wave of litigations in the ordinary courts in order to reach verdicts on his arbitrary anticonstitutional measures. Since Müller had acted without legal basis the courts usually proved the litigants to be right. On 3 February Müller decreed another ordinance to send functionaries against their will into early retirement. Müller thus further cleansed the staff in the consistories, the Evangelical Supreme Church Council and the deaneries from opponents. On 1 March Müller pensioned Niemöller off, the latter and his Dahlem Congregation simply ignored that. Furthermore, Müller degraded the legislative provincial synods and the executive provincial church councils into mere advisory boards. Müller appointed Paul Walzer, formerly county commissioner in the Free City of Danzig, as president of the March of Brandenburg provincial consistory. In the beginning of 1936 Supreme Consistorial Councillor Georg Rapmund, member of the Evangelical Supreme Church Council, succeeded Walzer as consistorial