Head of the Church time of the English Reformation, Henry VIII took for himself the title of Supreme Head of the Church of England, which was theologically problematic; his daughter Elizabeth I changed this to Supreme Governor of the Church of England. The Presbyterian system, codified in the Westminster Standards, outlines teaching elders (Ministers) and ruling elders, and courts presided over by Moderators sitting "primus inter pares", and gives practical effect to the concept of the equal status of all believers behind the one and only head of the church - Jesus Christ. This gives rise to the famous (or infamous) section of the
First Unitarian Church of Los Angeles Angeles to recover the property tax charges weighed by the County. Four years later, on June 30, 1958, the U.S. Supreme Court ruled in favor of First Church in court case: 357 US 545 First Unitarian Church of Los Angeles v. County of Los Angeles, California. In a 7 to 1 decision, with Justice Brennan writing for the majority opinion, the U.S. Supreme Court invalidated the State's loyalty oath requirement. (Chief Justice Earl Warren, who had signed the Levering Act when he was the Governor of California prior to joining the court on January 11, 1954, recused himself.) BURR was