From RLUIPA Defense - Court Dismisses RLUIPA Claims of Christian Rehabilitiation Center
Check out the post on RLUIPA Defense, the blog written by Dwight Merriam and Evan Seeman, for a great discussion of a recent case that dismisses a RLUIPA lawsuit filed by Candlehouse Teen Challenge, a Christian-based rehabilitation center. For a detailed discussion of the decision, visit RLUIPA Defense at New York Federal Court Dismisses RLUIPA Suit Involving Faith-Based Rehabilitation Center. A brief summary of the case follows.
Candlehouse had purchased a former church campus property to operate its proposed residential program, which property was zoned in the R-1 district. The ZBA determined that Candlehouse did not meet the definition of the functional equivalent of a family under the Town’s zoning code, concluding that "(1) the proposed assembly of students does not resemble a traditional family unit; (2) it is anticipated that the group will live and cook together as a single housekeeping unit; (3) Candlehouse students are anticipated to be transient in nature, rather than permanent, entering and leaving as they are either rehabilitated or expelled; and (4) the proposed bedroom would not be a ‘conventional’ bedroom but instead would contain rows of bunks for all students in one large room.” Candlehouse sued, claiming violations of RLUIPA, the Fair Housing Act, and the ADA.
The District Court found no evidence that the Town's conduct substantially burdened its religious exercise under RLUIPA. In particular, the Town's zoning ordinance permits Candlehouse to operate a residential facility for up to five unrelated persons. The court determined that Candlehouse failed to establish how precluding it from housing an additional seven students has “coerce[d] it to change how it operates its program in relation to its religious exercise.”
With respect to its other claims, the District Court declined to grant summary judgment in favor of the Town because there was at least some evidence to show that some of the members of the Board were biased against Candlehouse. In particular, at least two members of the Board spoke out against Candlehouse’s proposed use of the Property, with one member threatening to rezone the area to prohibit Candlehouse moving to the neighborhood.
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