See An Act Concerning the District of Columbia, 2 Stat. 128. Title to the glebe lands remained vested in the crown and passed to the new sovereign, the state of Vermont, at the outbreak of the Revolution. More than 30 years before Dartmouth College, the turmoil of Virginia's disestablishment prompted Marshall to consider the vested property of corporations and to answer the question of whether a legislature could repeal incorporation.Footnote 62. The case pitted the ascendant Democratic Republicans in the statehouse who supported disestablishment against the Congregationalists on Dartmouth's Board of Trustees. Eric Michael Mazur argues that Marshall relied on (but did not cite) Story's reasoning in Terrett and Pawlet in his decision in Trustees of Philadelphia Baptist Ass'n v. Hart's Executors (1819). These laws guaranteeing the parish's irrevocable rights to its property had been unconstitutionally revoked by an overeager legislature.Footnote 109. Gordon, The First Disestablishment, especially 31944. 98. In the 1820s, Virginia's vestries mounted another challenge to the 1802 Glebe Act citing Terrett. 1, 44344, LVA. Over the next decade, a host of colonial laws that had empowered the Anglican Church and penalized dissenters were overturned. Putnam's Sons, 1910), 1:77. For more on the importance of Dartmouth College, see Mark, Gregory A., The Personification of the Business Corporation in American Law, University of Chicago Law Review 54 (1987): 144183CrossRefGoogle Scholar; McGarvie, Mark D., Creating Roles for Religion and Philanthropy in a Secular Nation: The Dartmouth College Case and the Design of Civil Society in the Early Republic, Journal of College and University Law 25 (1999): 52768Google Scholar; Francis N. Stites, Private Interest and Public Gain: The Dartmouth College Case, 1819 (Amherst: University of Massachusetts Press, 1971); and Rodney A. Smolla, The Constitution Goes to College: Five Constitutional Ideas that Have Shaped the American University (New York: New York University Press, 2011). Scholars of colonial Virginia have focused solely on the ways in which statutory law underwrote the power of the established church while eliding common law from their accounts. Turpin and Terrett were not only connected by the similarity of their circumstances but also by the presence of Justice Bushrod Washington on the Supreme Court.

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