I've seen it queried by several (most recently by
phantomas, to whom I replied with the below in a comment) about the giant gaping loophole of someone possessing Sam's body can say yes to Lucifer WTF?
So, OBVIOUSLY, the underling demon who had the brilliant idea to bring Gary-in-Sam's-body to Lucifer for possession was kind of unclear on the concept of what archangel possession actually entailed. It's not like it's likely to have much experience with it. So I'm envisioning the demon summoning Lucifer and being all "Look see I got you Sam! You can have your Sam-shaped-vessel now just like you wanted aren't I the most awesome minion ever???!!!" and Lucifer being all *facepalm* THAT'S NOT SAM YOU TWINK DIAF.
We don't have confirmation from Lucifer that it would have worked, after all.
[/fanwank]
(I'm sure I'm not the only one who concluded this, I just thought I'd say it.)