Messiah Baptist Church v. County of Jefferson case brief

Messiah Baptist Church v. County of Jefferson case brief summary
859 F.2d 820 (1988)

CASE SYNOPSIS

Plaintiffs, a church and various individuals that represented a class, appealed from an order of the United States District Court for the District of Colorado which upheld the constitutionality of zoning regulations and that granted summary judgment to defendants, county and board of commissioners, in an action for damages under 42 U.S.C.S. §1983 alleging that the zoning regulations violated plaintiffs' rights under the first and fourteenth U.S. Constitutional amendments.

CASE FACTS
Plaintiffs, a church and various individuals representing a class, purchased vacant land zoned agricultural (A-2) and applied for a building permit for a new house of worship. Defendants, county and board of commissioners, denied the application because the A-2 zoning ordinances prohibited churches, even as special uses. Plaintiffs filed a 42 U.S.C.S. §1983 action for damages, contending that defendants' zoning regulations were unconstitutional under the Due Process Clause of U.S. Constitutional Amendment XIV and the Free Exercise Clause of First Amendment of the U.S. Constitution. Both parties moved for summary judgment.

PROCEDURAL HISTORY
The district court upheld the constitutionality of the zoning regulations and granted defendant's motion for summary judgment. Plaintiffs appealed.

DISCUSSION

• The court ruled that the A-2 regulations did not infringe upon plaintiffs' protected liberty interests, and affected only property interests, and therefore were constitutional because the regulations bore a substantial relationship to the general welfare of county residents and were not arbitrary or unreasonable. 
• The court held that the A-2 regulations did not regulate plaintiffs' religious beliefs or religious conduct. 
• Accordingly, the court affirmed.

CONCLUSION

• The court affirmed the order that upheld the constitutionality of defendants', county and board of commissioners, zoning regulations, granted defendants' motion to dismiss the action for damages filed by plaintiffs, a church and various individuals that represented a class, and denied the plaintiffs' motion for summary judgment. 
• The challenged zoning ordinances did not violate the plaintiffs' constitutional rights to due process nor did it violate their free exercise of religion.

See also: Messiah Baptist Church v County of Jefferson case (full text) on Google Scholar.

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