 In January 2004, Duncan was elected the first moderator of the Anglican Communion Network.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.