In the 1632 Charter of Maryland, King Charles I of England granted "all that Part of the Peninsula, or Chersonese, lying in the Parts of America, between the Ocean on the East and the Bay of Chesapeake on the West, divided from the Residue thereof by a Right Line drawn from the Promontory, or Head-Land, called Watkin's Point, situate upon the Bay aforesaid, near the river Wigloo, on the West, unto the main Ocean on the East; and between that Boundary on the South, unto that Part of the Bay of Delaware on the North, which lieth under the Fortieth Degree of North Latitude from the Equinoctial, where New England is terminated" to Cecil Calvert, 2nd Baron Baltimore, as the colony of Maryland. This would have included all of present-day Delaware; however, a clause in the charter granted only that part of the peninsula that had not already been colonized by Europeans by 1632. Over a century later, it was decided in the case of "Penn v Lord Baltimore" that, because the Dutch had colonized Zwaanendael in 1631, the portion of Maryland's charter granting Delaware to Maryland was void.