Candlehouse, Inc. v. Town of Vestal

Candlehouse, Inc. (plaintiff) operated Candlehouse Teen Challenge, a Christian nonprofit organization that provided faith-based residential treatment to young women struggling with addiction or emotional disorders. Candlehouse purchased two properties formerly used as a church and church campus in the town of Vestal, New York (defendant). Candlehouse intended to use the property as a church and dormitory-style residence for 12 future students who participated in the program. The area where the property was located was designated as a residential district for zoning purposes. Vestal’s zoning code permitted properties in the residential district to be used for one-family homes or boarding houses with a maximum of two transient occupants. The code prohibited the use of land in the residential district for boarding houses, charitable institutions, and multi-family dwellings. Candlehouse argued to the code enforcement officer that the proposed use of the property constituted the functional equivalent of a family under the town code. The enforcement officer responded that Candlehouse did not meet the functional equivalent of a family and thus did not comport with the town’s zoning code. Candlehouse appealed to the town’s zoning board of appeals, but the zoning board ultimately agreed with the code enforcement officer. Candlehouse argued to the board that its program was protected by the Fair Housing Act (FHA) and the Americans with Disabilities Act (ADA) and that Vestal should grant a reasonable accommodation by waiving or amending the zoning ordinance to permit Candlehouse’s use. Candlehouse also alleged that Vestal’s restriction on its use of the premises violated the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA). Vestal refused, and Candlehouse sued in district court alleging Vestal violated the FHA, ADA, and RLUIPA.