 John of Paris (d. 1306) reasserts the traditional distinction between ownership and  rulership.[59]  The fact that a ruler adjudicates property disputes does not make him supreme owner. A community (a state, or the Church, or particular communities) acquires property only from individuals, and the head of the community is the administrator of the community’s property, not its owner. This is true also of the pope, who does not have unrestricted power over Church property, still less over the properties of lay people  (96–105).[60]  John’s assumption that original appropriation is by individuals, and his remark that individuals acquire property by “labour and industry” (86, 103), have led to suggestions that he anticipated Locke’s theory of property. However, John indicates that individuals acquire property under human law (148, 154,  225–6),[61]  which is the view traditional among medieval theologians, following Augustine (see  §4.3).  Property is acquired under human law, but it is acquired by individuals, not directly by rulers.