to a member of the family, sometimes for more than one generation. Sometimes the donation was revocable upon the possible return of a distant heir. Other conditions might preclude it as ever being awarded as a benefice, on penalty of reverting to the family. The usufruct might be reserved to a female (ancilla dei) or a male as yet unborn, let alone not yet in Holy Orders, and allowed the donor to make provision for the support of family members. A donation couched in such terms to a third party, served to provide some protection against subsequent challenges by other family members. Ulrich Stutz argued that the institution of the proprietary church existed particularly in areas that had never been Roman, among the Irish and the Slavs, and in the Eastern Roman Empire, but the proprietary church is best known in Germany, where the Grundherr, the landlord who had founded the church on his property and endowed it from his lands, maintained the right of investiture, as he was the advocatus (German Vogt) of the fief, and responsible for its security and good order. In the 9th and 10th centuries the establishment of proprietary churches in Germany swelled to their maximum. The layman who held the position was a lay abbot. The altar was the legal anchor to which the structures, the land, the rights and ties were attached. The proprietor and his heirs retained unabated legal rights to the ground on behalf of the saint whose relics lay beneath the altar. "He could sell, lend or lease the altar, leave it to his heirs, use it for dower, or mortgage it, provided that a church, once dedicated, continued to be used as a church." However, the founder could not alienate any of the land or appurtenances designated for the maintenance of the church and support of the priest. Dedicating land for a religious use was one way to preserve it from being partitioned into parcels too small for effective economic use. According to George W.O. Addleshaw, French historians attribute the development of proprietary churches to the decentralization that ensued with the collapse of the Roman Empire in the West and the increased authority of late Roman and Merovingian landowners, who assumed responsibility for rural churches in lieu of bishops in their urban sees. Later Middle Ages The proprietary right could be granted away or otherwise alienated, even for a