In 2003, Calvary Episcopal Church in East Liberty sued the diocese and its bishops, Duncan and Scriven, specifically over actions taken by a special convention the diocese held after the Episcopal Church's 2003 General Convention. At the special convention, the diocese had passed a resolution that asserted that all property of individual parishes belonged to the parishes themselves, rather than to the diocese. In the suit, Calvary claimed that the diocese could not take such an action, as it violated the Dennis Canon which states that parish property is held in trust for the diocese and the national church. The parties signed a court-approved settlement in October 2005. The settlement confirmed that all diocesan property would remain the property of "The Episcopal Diocese of Pittsburgh of the Episcopal Church U.S.A." even if a majority of parishes left the Episcopal Church. It also created a process by which the diocese agreed to make decisions about property and assets should a congregation wish to leave the diocese.