Scottish Episcopal Church choose a bishop. Each diocese has one or more (in the case of some united dioceses) cathedrals. The senior priest of a Scottish Episcopal cathedral is styled as provost (as the title of 'dean' is given to the senior priest of the diocese as a whole, see above). The only exception in Scotland is the Cathedral of the Isles on the island of Great Cumbrae which has been led by a member of the clergy styled as Precentor. Diocesan deans and cathedral provosts are both addressed as "Very Reverend". The Scottish Episcopal Church is mainly in the High Church (or
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