was a land grant which was given in deed of bargain and sale on 18 September 1770 by the direction of the then vestry of the church. The land had been conveyed to Townsend Dade and James Wren, both of the county and 44 other church wardens, and to their successors in office in a form of for the use and benefit of the said church in the said parish. Society for Propagation of the Gospel v. Town of New Haven (1823) The 1823 case of Society for the Propagation of the Gospel v. Town of New Haven looked at the issue of lands granted to an English corporate body, the "Society" which had a religious purpose. The land had been granted by King George III of Great Britain in New Hampshire in 1761. It was held in corporation by a form of . On 30 October 1794, the State of Vermont passed a statute whereby the land of the Society would be appropriated by the state. The Supreme Court was divided in its opinion. It ruled that the property of English corporations at the time of the Revolution were protected by the Treaty of Peace, 1783. See Treaty of Paris (1783), Treaty of Versailles (1783). There could be no confiscations of such corporate holdings or lands because of the treaty. Beatty v. Kurtz (1829) In the 1829 case of Beatty v. Kurtz the United States Supreme Court decided the issue of title in an unincorporated Lutheran Church land. The land had been used as a cemetery. The fact that the land was held by a non-corporation was deficient at law. Nevertheless, equity permitted settlement of the title in the favor of the church organization out of religious sensitivity and sensibility. There should be sentiments for the kindred of the deceased. Goesele v. Bimeler (1852) A group of German separatists settled land in Ohio. The lands were held in community, and there was a renunciation of individual property. All crops and goods were donated to the community. Later the community formally incorporated, using the terms of the previous unincorporated association. The nature of the holding was in the form of a traditional . The heirs of a deceased member of the Society of Separatists sued, seeking a portion of the lands held in community. In Goesele v. Bimeler (1852), the United States Supreme Court ruled that the descendant heirs of