In a later chapter of the dispute which sparked Schofield v. Superior Court (2010) 190 Cal.App.4th 154, the court holds that Schofield, the disaffected bishop of the San Joaquin Diocese, lacked authority on his own to amend the canons of the corporation sole in whose name the diocese’s property was held, and he had not secured the required approval of the diocese’s convention for the amendment he tried to make. Hence, the amendment was invalid as were the transfers of the diocese’s property which the bishop undertook pursuant to the invalid amendment.
California Court of Appeal, Fifth District (Levy, Acting P.J.); April 5, 2016; 2016 WL 1319742