 The legality of Virginia's confiscation of the Northern Neck Proprietary lands continued to be contested in state and federal courts long after Denny Fairfax's death in 1800.The Virginia Supreme Court upheld the state's confiscation and conveyance of the proprietary's lands, arguing that the terms of the Jay Treaty with the Kingdom of Great Britain did not address the disputed proprietary.In 1813, the United States Supreme Court reviewed the Virginia Supreme Court's decision in "Fairfax's Devisee v. Hunter's Lessee", 11 U.S. 603, and ruled that the treaty did in fact cover the dispute, and remanded the case back to the state supreme court.