The Very Reverend of a cathedral, whether a dean or a provost, is usually styled as "The Very Reverend" regardless of whether the priest is also the rector of the cathedral parish, or whether the cathedral is a parish church. In the Episcopal Church USA, the dean of a seminary or divinity school is also styled in this form, as is the priest who is either appointed by the local bishop or elected by fellow priests as the leader of a deanery, which is a geographic subdivision of a diocese. In some Episcopal dioceses convocation is used in lieu of deanery. The deans
Aboriginal title in the United States acquired post-sovereignty; a "long time" can mean as little as 30 years. However, the requirement of exclusivity may prevent any tribe from claiming aboriginal title where multiple tribes once shared the same area. Improper designation of an ancestral group may also bar acknowledgement. 'Cramer v. United States' (1923) was the first Supreme Court decision to acknowledge the doctrine of "individual" aboriginal title, not held in common by tribes. Individual aboriginal title may be an affirmative defense to crimes such as trespassing on US Forest Service lands. However, a claimant asserting individual aboriginal title must show that his or her ancestors