Episcopal Student Foundation v. City of Ann Arbor

The Episcopal Student Foundation’s Canterbury House (Canterbury) (plaintiff) filed a 42 U.S.C. § 1983 action against the City of Ann Arbor (City) and its Historic District Commission (Commission) (defendants), in which Canterbury claimed that the City’s denial of a demolition permit for its worship facility violated the federal Religious Land Use and Institutionalized Persons Act (RLUIPA). Canterbury was a religious organization that operated a religious services center in a historic district for local university students, including worship services, concerts, and community meals. Canterbury also rented out a large portion of its facility to commercial tenants. After experiencing significant growth, Canterbury applied for permits to demolish its facility and replace it with a larger one to accommodate its expanding congregation and meal service. The Commission denied the application, and the State Historic Preservation Board affirmed the denial. Canterbury filed its RLUIPA action on the grounds that denial of the permits substantially burdened Canterbury’s free exercise of religion by impeding its ability to engage in religious exercises that required additional space. The City countered that Canterbury’s free exercise of religion was not substantially burdened and also that RLUIPA was itself unconstitutional. Both parties moved for summary judgment.