3

Worldwide Church of God, Inc. v. State, 623 F.2d 613 (9th Cir. 1980), cert. denied, 449 U.S. 900 (1980). See generally Note, 53 S. CAL. L. REV. 1277 (1980). The California state legislature enacted a new statute in 1980 giving the attorney general authority to investigate religious corporations whenever he had reasonable grounds to believe that corporate property had been improperly diverted for the personal benefit of any individual, or that a substantial diversion of corporate assets from stated corporate purposes had occurred.