In the past decade scholars such as Stanford Lehmberg. G. R. Elton, and J. G. Bellamy have increased our understanding of the use of parliamentary attainder in the reign of Henry VIII. Traditionally attainder had been used to punish fugitives in flight, a form of parliamentary outlawry, or to affirm and supplement prior convictions achieved through the common law or the law of arms in order to extend the crown's rights to forfeited estates. At common law a traitor's forfeiture was limited to lands in fee simple, and by the law of arms his lands were totally immune to forfeiture. Passage of an act of attainder, however, enabled the king to seize any or all of a traitor's land, whether held in fee simple, fee tail, or to the use of the traitor. In the crucial decade of the 1530s attainder assumed a new role, condemning and ordering the execution of offenders solely by authority of parliament, without any prior judicial proceedings and despite an absence of obstacles which might have made a trial impossible. Lehmberg emphasizes the significance of this transformation in his detailed study of attainder in the reign of Henry VIII and suggests that the ‘pivotal act’ was the attainder of Elizabeth Barton and her followers in 1534. Certainly Barton's attainder was the first of many utilized by Henry's government to enforce the Reformation, and it did so without recourse to the common law. Lehmberg is mistaken, however, in his belief that this was the first attainder of the reign to attaint an individual without prior common law proceedings, for that distinction belongs to the attainder of Richard Roose in 1531.