Adam Community Center v. City of Troy

In 2013, Adam Community Center (the center) (plaintiff) purchased a commercial property in the City of Troy, Michigan (the city) (defendant). The center intended to use the commercial building as a place for Muslim religious worship, a community center, a library, a gym, and a banquet hall. The city did not have any other places of Muslim worship. The property purchased by the center was in the general business district, where places of worship were allowed as a matter of right. However, in 2017, the city enacted zoning ordinances sections 6.21(E) and 6.21(F). Section 6.21(E) required all places of worship to have a 50-foot setback on each side of the building. Section 6.21(F) forbade parking in setback areas that faced residentially zoned areas and required landscaping such setbacks. The center could not comply with the ordinances, so the center applied to the city for a variance. After a public hearing, the zoning board unanimously denied the center’s application. The center sued the city, alleging that the variance denial violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) because the lack of a Muslim place of worship in the city substantially burdened the ability of the center’s members and other Muslims in the city to practice their religion. The center also alleged that the zoning ordinances were unconstitutional because the ordinances applied preferential treatment to commercial businesses over religious institutions. The city moved to dismiss, arguing that the center had failed to establish a substantial burden under RLUIPA.