Massachusetts Bay is the standing case study in how quickly a persecuted body becomes a persecuting one. Roger Williams was banished in October 1635 for arguing that the civil magistrate had no jurisdiction over the first table of the law and that the colony's land title was invalid; he founded Providence and, in 1638, the first Baptist church in America. Four Quakers, including Mary Dyer, were hanged on Boston Common between 1659 and 1661 for returning after banishment. Baptists were whipped and jailed for holding services. The colony required church attendance and funded ministers by tax, and Congregationalism remained the established church of Massachusetts until 1833, the last establishment in the United States to fall. The tradition's own later history is a long reckoning with this, and it produced some of the sharpest American arguments for disestablishment, made by Congregationalists.