Kaahumanu v. County of Maui

Sandra Barker (plaintiff) ran a commercial wedding business in the County of Maui (Maui) (defendant) and arranged wedding ceremonies at her beachfront home in a residential area. Barker also provided access through her property for wedding ceremonies on a public beach. Pastor Laki Kaahumanu (plaintiff) conducted some of the ceremonies arranged by Barker. In 1998, Barker applied for a conditional-use permit (CUP) to continue to use her beachfront property as a commercial wedding venue. Because Barker’s proposed use of her property was not one of the designated special uses in the Maui County Code, Barker had to apply for a CUP, which could only be granted by an ordinance enacted by the Maui County Council (the Council) (defendant). On June 17, 1999, the Maui Planning Commission recommended that the Council approve Barker’s application. However, the land-use committee recommended rejection, and the Council rejected Barker’s application. On November 24, 2000, Barker and Kaahemanu were cited for performing commercial weddings on residential property. Barker and Kaahemanu sought relief against the Council and its members (defendants), in their individual and official capacities, under 42 U.S.C. § 1983 for violations of the First, Fifth, and Fourteenth Amendments, as well as the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. § 2000cc. The defendants moved to dismiss the claims against the Council members in the members’ individual and official capacities, arguing that the individual-capacity claims were barred by legislative immunity and that the official-capacity claims were duplicative of the claims against Maui. The district court granted the motion to dismiss the official-capacity claims but allowed the individual-capacity claims to go forward. The Council members, in their individual capacities, appealed the district court’s denial of legislative immunity.