Clement VIII died in March 1605, and the attitude of his successor Pope Paul V strained the limits of papal prerogative. Venice simultaneously adopted measures to restrict it: the right of the secular tribunals to take cognizance of the offences of ecclesiastics had been asserted in two leading cases and the scope of two ancient laws of the city, that were: one forbidding the foundation of new churches or ecclesiastical congregations without the consent of the state, the other forbidding acquisition of property by priests or religious bodies. These laws had been extended over the entire territory of the republic. In January 1606, the papal nuncio delivered a brief demanding the unconditional submission of the Venetians. The senate promised protection to all ecclesiastics who should in this emergency aid the republic by their counsel. Sarpi presented a memoir, pointing out that the threatened censures might be met in two ways – "de facto", by prohibiting their publication, and "de jure", by an appeal to a general council. The document was well received, and Sarpi was made canonist and theological counsellor to the republic.