In the year 1867 the Right Rev. Bishop Coxe, of the Western Diocese of New York, refused the sacrament to those women patients of Dr. Foster’s Sanitarium at Clifton Springs, N. Y., whose heads were uncovered, although the rite was performed in the domestic chapel of that institution and under the same roof as the patient’s own rooms.

During the famous See trial at Newark. N. J., 1876, the prosecutor, Rev, Dr. Craven, declared that every woman before him wore her head covered in token of her subordination.