In Episcopal Church Cases (2009) 45 Cal.4th 467, after a local church disaffiliated itself from the larger general church, the two churches claimed ownership of the local church's property and the building on the property. (Id. at p. 472.) The defendants argued that the lawsuit arose from the protected activity of expressing disagreement with the higher church authorities concerning church governance and then in disaffiliating from the general church. (Id. at p. 477.) The Supreme Court disagreed, holding that while the protected activity "lurked in the background of this case, the actual dispute concerned property ownership rather than any such protected activity" within the meaning of section 425.16. (Id. at p. 473.) The Supreme Court explained, "'the mere fact that an action was filed after protected activity took place does not mean the action arose from that activity for the purposes of the anti-SLAPP statute. . . . In the anti-SLAPP context, the critical consideration is whether the cause of action is based on the defendant's protected free speech or petitioning activity.' In filing this action, the Los Angeles Diocese sought to resolve a property dispute. The property dispute is based on the fact that both sides claim ownership of the same property. This dispute, and not any protected activity, is 'the gravamen or principal thrust' of the action. The additional fact that protected activity may lurk in the background--and may explain why the rift between the parties arose in the first place--does not transform a property dispute into a SLAPP suit. Accordingly, the trial court erred in treating this as a SLAPP suit subject to section 425.16's special motion to dismiss." (Episcopal Church Cases, supra, 45 Cal.4th 467, 477-478.) In Episcopal Church Cases (2009), a doctrinal dispute arose between a local Episcopal parish and the Protestant Episcopal Church in the United States of America (the national church). The local parish and its members objected to the ordination by the national church of an openly gay bishop in New Hampshire and voted to disaffiliate the parish from the national church. In response, the local Episcopal diocese and the national church brought an action to recover church property from the local parish and various individuals associated with the parish. In particular, the diocese and the national church sought to recover the church building and land on which the building sits. Among other matters, the local parish and the individuals brought an anti-SLAPP motion, which the trial court granted. The Court of Appeal reversed, and on review, the Supreme Court affirmed the Court of Appeal: "In filing this action, the Los Angeles Diocese sought to resolve a property dispute. The property dispute is based on the fact that both sides claim ownership of the same property. This dispute, and not any protected activity, is 'the gravamen of principal thrust' of the action. The additional fact that protected activity may lurk in the background -- and may explain why the rift between the parties arose in the first place -- does not transform a property dispute into a SLAPP suit." (Episcopal Church Cases, supra, 45 Cal.4th at pp. 477-478, second italics added.)