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October 25, 2018 I Volume 12 I Issue 20 Zoning Bulletin <br />Case Note: <br />FLFNB had also alleged that the Ordinance and related park rule were "unconsti- <br />tutionally vague." The district court disagreed. On appeal, the Eleventh Circuit <br />also returned that issue on remand (with little related comment or direction) for <br />the district court to address. <br />Religious Freedom —City denies <br />use of single-family home as <br />church's "meeting house" <br />Church contends denial violates its religious freedom <br />rights <br />Citation: Roman Catholic Archdiocese of Kansas City in Kansas v. City <br />of Mission Woods, 2018 WL 4154034 (D. Kan.. 2018) <br />KANSAS (08/30/18)—This case addressed the issue of "whether a <br />municipality's exercise of its zoning power infringed on a church's <br />religious freedom." <br />The Background/Facts: In 2015, the Roman Catholic Archdiocese of <br />Kansas City in Kansas and St. Rose Philippine Duchesne Catholic Church <br />(the "Church") bought a house in a Residential District in the City of Mis- <br />sion Woods (the "City"). The house had been used as a single-family home. <br />The Church intended to use the house as a "meeting house" for various <br />groups —including prayer and Bible study groups. <br />In the City's Residential District, properties could only be used for <br />single-family houses and certain "public" or "semipublic uses." Approved <br />"public" and "semipublic" uses included churches and synagogues, com- <br />munity centers, and schools. Public use of land within the Residential <br />District required City Plan Commission and City Council approval, which <br />included those bodies finding that certain prerequisites had been met. <br />Because the Church intended to use the house in a semi-public fashion, <br />it filed an application asking the City to approve the semi-public meeting <br />house use. The City proposed limitations on the hours of use and number <br />of people using the house. However, the Church rejected those proposed <br />limitations. With concerns about noise and traffic, the City ultimately <br />refused to allow the Church to use the house as a semi-public space. <br />The Church then sued. Among other things, the Church argued that, in <br />preventing it from using the proposed meeting house, the City imposed a <br />substantial burden on the Church's religious exercise in violation of the <br />federal Religious Land Use and Institutionalized Persons Act ("RLUIPA"). <br />RLU1PA's substantial burden provision provides that: <br />8 © 2018 Thomson Reuters <br />