Secondly, there must be some kind of fiduciary relationship between the claimant and the defendant. Often cases are brought by the Crown according to the complaint of a claimant. This is not easily quantifiable, and depends on the individual circumstances of the claimant. Often this involved trying to determine which party was a legal claimant. He therefore found the favour of the claimant. Property torts involve any intentional interference with the property rights of the claimant. He was replaced by the Yorkist claimant, Edward IV, who ruled until his death. Littlejohn suggested incorrectly Monroe was an unemployed welfare claimant. Reducing the amount of paperwork needed by the claimant and council. In 1360, however, he agreed to relinquish his title to the French claimant. The change was not acknowledged by Jacobite claimant Cardinal Henry Benedict Stuart. Those churches rejecting Brigham Young's leadership, in favor of some other claimant. Matusevitch replied accusing the claimant of being a racist. Robert Bruce, 5th Lord of Annandale, the next strongest claimant, accepted this outcome with reluctance. At one point, there was at least nominally a "sixth" claimant to the Patriarchate.