Of course, CA had the most, but Massachusetts had over 500 and Tennessee had over 200 take the exam in 2012. Does this mean that states are starting to become more lenient?
No, I don't think so, and here is why:
California is not the only state that allows state-accredited law schools to operate within it's borders. Massachusetts, Tennessee, and Alabama also have non-ABA state accredited schools, and have been allowing their graduates to sit for the bar for decades. Therefore, this does not represent a new openness on the part of these states, but rather reflects what has been going for a long time.
Massachusetts did recently admit a Concord grad after he passed the bar and filed suit to gain admission, and perhaps that will open the door for others in that state. Most state bars remain openly hostile to non-ABA graduates, especially those graduating from unaccredited correspondence/online programs.
As far as the P&I argument, it will be played out over the next few years as online grads challenge state bars for admission. I don't think it will work in most cases, however, since state bars are likely to be viewed as acting within their permissible scope to set educational standards for admission. Historically, state bars have a lot of latitude in controlling admission, and the argument may fall on unsympathetic ears.
Lastly, the discussion surrounding ABA/non-ABA often focuses on the exclusivity and snobbiness of the ABA and the various state bars. While I think there are legitimate criticisms to be made in that arena, at some point the non-ABA schools are going to have to meet the bar associations halfway if they want to be taken seriously. It's not enough to just demand respect, they've got to earn it, and that means turning out students who can pass the bar. It's not just elitism that makes people suspicious of schools that have 10% bar pass rates.
Online schools are going to have to start requiring college degrees, the LSAT, and other basic admissions criteria along with serious academic support and attrition of underperformers. Until then, I don't think much will change.