[Apocrypha]

Its called putting "Poision Pills" in your bylaws and constition. You put scriptural references to as many things in there as you can. Judges are VERY very loathe to mess with anything that smacks of religion due to bad precedent. From what I gather the church had bylaws/consitution that made it tough for a judge.

The bylaws a consitution of my church have similar things in them for similar reasons (not evil like what he did, but to avoid litigation if some saints want to force something in court based on technicalities).

The judge should have been smart enough to rule on it either way and decide if it was "unjust enrichment" of officials of a non-profit... which is pretty easy to decide on using various common sense tests.

Losing the 800k on a "energy scheme" could be trickier since churches invest money in various things like stocks/bonds/muni funds and it would depend on many factors to see if it was unlawful conversion of funds and if the board agreed to it according to the bylaws.