Tuesday, December 24, 2013

Guru Nanak Sikh Society of Yuba City v. County of Sutter case brief

Guru Nanak Sikh Society of Yuba City v. County of Sutter case brief summary
456 F.3d 978 (2006)

Defendant county appealed a decision of the United States District Court for the Eastern District of California, which granted summary judgment to plaintiff religious group in its action, which alleged that the county violated the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C.S. § 2000cc et seq., when it denied the group's application to build a temple on land zoned agricultural.

The group was denied a conditional use permit to build a temple on a 1.89-acre parcel that was zoned residential. It then sought a permit to build a smaller temple on a 28.79-acre parcel that was zoned agricultural. It agreed to accept all of the county planning division's conditions on the land's use. Although the planning commission gave its approval, the county board of supervisors denied the group's application because the temple would contribute to "leapfrog development."


  • In affirming the district court's grant of summary judgment to the group, the court held that the county's denial constituted a substantial burden under the RLUIPA because the stated reasons behind the denial and a previous denial of the application to build the temple on a parcel of land zoned residential, to a significantly great extent lessened the possibility of the group constructing a temple in the future. 
  • The court also held that the RLUIPA was a permissible exercise of Congress's remedial power under the Fourteenth Amendment because it targeted only regulations that were susceptible, and had been shown, to violate individuals' religious exercise.
The court affirmed the district court's decision.

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