With the childless death of Anne Mowbray, 8th Countess of Norfolk, in c.1481, the Barony went into abeyance between the Howard and Berkeley families, and both styled themselves Baron Mowbray and Seagrave.

[2] In 1639, Henry Frederick Howard, later 22nd Earl of Arundel, was summoned to Parliament as Baron Mowbray, which by modern usage would have represented a novel peerage, but an 1877 House of Lords ruling viewed this as affirmation of the prior termination of the abeyance of the original title.

[2] In 1877 the senior co-heir, Alfred Stourton, Lord Stourton, petitioned the House of Lords to have the abeyance terminated in his favour, and though the original claim was for the resolution of the abeyance of the 1639 grant, a subsequently amended petition made a broader claim.

A c.1484 royal letter in which John Howard, Duke of Norfolk, was given the assumed titles of Baron Mowbray and Seagrave was used as evidence that the abeyance of the 1283 peerage had been terminated in Howard's favour; there was no Berkeley representative in the hearing to point out that family had also used those assumed titles.

The Committee for Privileges in the Mowbray-Seagrave Case ruled in Stourton's favour,[3] and in 1878 the original Barony of Mowbray, and then two weeks later the associated Barony of Seagrave, were called out of abeyance in favour of Lord Stourton.