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 While—under "Ex parte Young"—tribes may obtain some prospective, equitable relief in suits nominally against state officials (generally, for treaty rights), the Supreme Court in "Idaho v. Coeur d'Alene Tribe" (1997) held that state sovereign immunity barred not only quiet title suits but also suits against state officials which would constitute the equivalent of quiet title. Although "Coeur d'Alene" involved sovereign title to a lake bed, this precedent has been applied to bar even suits against states in their capacity as ordinary property owners. There are at least two Congressional statutes which may have contemplated authorizing aboriginal title suits against states: