The common law of England—law made by court precedent, rather than through legislation—was adopted by the United States in its early days. The common law included the offence of being a common scold. In 1829, a Philadelphia, Pennsylvania court found American writer and journalist Anne Royall guilty of being a common scold. Royall had objected to a firehouse, built with federal money, being used by a small church for their services. She thought this violated the U.S. Constitution's separation between church and state. The local clergymen campaigned to have her punished as a common scold. Hoping the court would sentence Royall to ducking, sailors at the Navy Yard built a ducking stool. However, the Pennsylvania court ruled that the punishment was not to be used any longer. They instead fined Royall ten dollars. In 1972, in the case of State v. Palendrano, 293 A.2d 747, New Jersey State prosecutors charged a woman with being a common scold for a disturbance she had caused. The New Jersey Superior Court ruled that the law was improper because of it was too vague.