This was directly applicable to the St Mary's Rector, Wardens, and Vestry cases, since in 2012, Judge Linfield accepted William Lancaster's argument that he should apply the “principle of government approach.” His ruling was reversed on appeal in 2014. In addition, Glenn Baaten, now a parishioner at the St Augustine of Canterbury Ordinariate group in Oceanside, CA, was briefly ordained in the ACNA at St James Newport Beach, although this was only for a period of months between January 2013 and May of that year, when the parish property was returned to the Episcopal Diocese of Los Angeles. Despite the considerable differences in theology between Presbyterians and Anglicans, the ACNA seems happy to have said, "Poof, you're an Anglican priest!" It appears that the US-Canadian Ordinariate is on the verge of making Mr Baaten a priest there, too, although if it's to be done this year, as the prediction goes, they'd better hurry.
However, the story for St James doesn't end in 2013. After the breakaway groups took the several parish properties in 2004, the Episcopal diocese made the rump Episcopal parishes missions, which means their temporal affairs were directly under the control of the bishop, not their respective rectors, wardens, and vestries. This meant that the bishop could sell the properties if he chose once the diocese regained legal title to them. Recognizing how destructive such moves can be, this may have been the only realistic option for most of the parishes-now-missions. In fact, the idea of selling properties after reclaiming them from dissident factions may have been at the root of the ACA's and Mr Lancaster's overall strategy for St Mary of the Angels from the designation of the Patrimony of the Primate in 2011, since the California Supreme Court ruled on "the Episcopal Church cases" in 2009 (although its ruling went opposite Mr Lancaster's reading of the law).
In St James's case, Episcopal Bishop of Los Angeles J Jon Bruno originally promised the parish-now-mission that it would not be sold. However, since St James was now canonically a mission (and probably in its restored form still too small to pay a diocesan tithe), Bishop Bruno didn't need its permission to sell its property, and when he decided in early 2015 to sell the place rather than keep it as he'd promised, he didn't ask for it. He simply signed an agreement to sell it and told the group what he'd done.
In July of this year, former members of the now-disbanded St James mission filed charges against Bishop Bruno, alleging 140 canonical violations, including "conduct unbecoming", deceit, and bullying. Par for the course, I would say, for an Episcopal Bishop, although my wife and I thought he was OK during the 11 years or so he was bishop and we were Episcopalians -- we prayed for him during two serious health crises, and we thought the diocese managed the transition from Fr Barbour to Fr Davies at St Thomas Episcopal Hollywood very well.
Looking back, I wish my Episcopal confirmation class had covered the high church-broad church-low church issue. I would have understood many things better at the time, and perhaps some groups that wanted to break away after the consecration of V Gene Robinson would have understood them better, too, and possibly made different and less destructive choices.
