I don't believe that is correct. In some cases, the locals have legal title to their property, in some of those cases there are express trusts in favor of the Diocese, in other cases, there is no express trust. Absent an express trust, the bishop has to argue that he has superior rights under the Dennis Cannon. In some states, that may work; in others, like California, it likely will not.
So the first stop should be at the county courthouse to see what the papers say about title under civil law, and then consult an experienced real estate attorney to see what credit, if any, the state will give to canon law.
Of course, if the bishop holds legal title, the question is much simpler.
As applied to this case, the local church appears to have held legal title, which they conveyed to a corporate structure. (There can be reasons for doing this apart from planning to split from the denomination).
Of course, the inverse of all of this can be seen in the bankrupt Catholic diocese, where the Bishop holds title to all of the property, but is claiming that he holds it in trust for the Parish. (I'd like to see how fast he'd change his tune if a Catholic parish tried to walk with 'its' property.)
In some cases in Virginia, the Church predates the Diocese! These Churches have already done the property title search on their property and are "ready" to fight in Court, if/when it becomes necessary.
I think there are no less than 2 Churches in Alexandria that date back to George Washington, where he not only worshipped there but I think might have started the Church - "old" Truro parish in Alexandria is one of them. (Washington was also known to have worshipped at the "other" Truro, in the heart of Fairfax City, but the building that he actually worshipped in burned down and was replaced by what is now the Chapel, completely stone outside but with beautiful wood inside. I digress.
Those Churches whose deeds predate the Diocese are prepared to "walk" with their property since I think one of them has already tested the legality in Court, and the Court decided for them. I also believe this involved several Dioceses as there is the Diocese of Virginia, the Diocese of Southern Virginia and perhaps another one as well (Diocese of SW VA?). My Blue book is still packed, and I can't check it for the number of Dioceses in the state, so forgive me if I'm inaccurate as to the number in VA.