In Trustees of Diocese of Albany v. Trinity Episcopal Church of Gloversville (250 AD2d 282, 684 NYS2d 76 [3d Dept 1999]), the Third Department noted that in many ways Dennis Canon I.7.4 was adopted in response to Jones v. Wolf, which "held that the constitution of a hierarchical church can be crafted to recite an express trust in its favor concerning the ownership and control of local church property" (Trinity, 250 AD2d at 285, citing Jones, 443 US at 606). The Third Department affirmed the judgment granted in favor of the diocese, concluding--despite the existence of deeds indicating that the local parish held unrestricted title to three parcels of land surrounding the church--that the property was held in trust for the benefit of the diocese and hierarchical church.