Adam Cmty. Ctr. v. City of Troy
381 F. Supp. 3d 887 (2019)
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Rule of Law:
A religious organization states a plausible claim for relief under the Religious Land Use and Institutionalized Persons Act (RLUIPA) when it alleges that a city's zoning regulations and the denial of a variance impose a substantial burden on its religious exercise by effectively preventing it from establishing a place of worship within the city, where no feasible alternatives exist.
Facts:
- Adam Community Center, a Muslim non-profit organization, sought to establish the first mosque in the City of Troy, Michigan, as its members had no local place for congregational worship.
- Since 2013, the Center's attempts to secure a property were unsuccessful, and it alleged that city officials displayed animus and suggested it look for property in other cities.
- In 2017, the City of Troy enacted a new zoning ordinance, Section 6.21, which imposed stricter requirements for places of worship compared to commercial buildings, including a 50-foot setback on all sides.
- The Adam Community Center purchased an existing commercial property located in a general business district, where places of worship were a permitted use.
- The purchased property could not meet the new 50-foot setback requirement, as it had only a 48-foot rear setback and existing parking that would be eliminated if the ordinance were strictly enforced.
- The Center applied to the City of Troy Zoning Board of Appeals (ZBA) for a variance from the specific setback requirements applicable to places of worship.
- On June 19, 2018, the ZBA held a public hearing and unanimously denied the Center's variance application.
Procedural Posture:
- Adam Community Center filed a lawsuit in the United States District Court for the Eastern District of Michigan against the City of Troy, its City Council, Planning Commission, Zoning Board of Appeals (ZBA), and individual ZBA members.
- The complaint alleged violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA) and 42 U.S.C. § 1983, along with state law claims.
- The Court previously dismissed the Plaintiff's state law claims for lack of supplemental jurisdiction.
- The Defendants filed a motion to dismiss the remaining federal claims for failure to state a claim under Fed. R. Civ. P. 12(b)(6), or alternatively, for summary judgment under Fed. R. Civ. P. 56.
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Issue:
Does a religious organization state a plausible claim for relief under the Religious Land Use and Institutionalized Persons Act (RLUIPA) by alleging that a city's specific zoning ordinances and subsequent denial of a variance application impose a substantial burden on its religious exercise when there are no other suitable properties available for a place of worship within the city?
Opinions:
Majority - Judge Nancy G. Edmunds
Yes. A religious organization states a plausible claim for relief under RLUIPA by alleging that a city's zoning ordinances and denial of a variance impose a substantial burden on its religious exercise. The court found that the Adam Community Center's complaint sufficiently alleged a substantial burden by claiming that: there are no Muslim places of worship in the City, no other suitable properties are available that meet the City's strict zoning requirements, and the ZBA's denial prevents its members from engaging in religious exercise. The determination of a 'substantial burden' is a fact-intensive inquiry involving factors such as the availability of alternative locations, the delay and expense caused by the regulation, and whether the burden was self-imposed. Such an analysis is improper at the motion-to-dismiss stage. The court also rejected the defendants' arguments for legislative immunity, finding the denial of a specific variance to be an administrative, not legislative, act.
Analysis:
This decision underscores the high bar for municipalities seeking to dismiss RLUIPA claims at the pleading stage. By finding the plaintiff's allegations of a lack of alternative locations and discriminatory animus sufficient to state a 'substantial burden' claim, the court affirmed that such cases are typically too fact-intensive for early dismissal. The opinion also reinforces the important distinction between legislative and administrative acts in the context of immunity; denying a specific variance application is an administrative act that does not afford officials the protection of absolute legislative immunity. This case serves as a guide for plaintiffs on how to plead RLUIPA claims effectively and puts municipalities on notice that they must be prepared to defend the merits of their zoning decisions rather than relying on procedural dismissals.
