St. Bartholomew’s Church v. City of New York

St. Bartholomew’s Church (the church) (plaintiff) was a nonprofit religious corporation located in New York City (the city) (defendant). The church complex consisted of a main house of worship and an auxiliary community house, both of which were designated as historic landmarks under the city’s landmarks law for their architectural and historical significance. The community house hosted the church’s various religious and charitable programs. Because of space issues, the church applied for permission to replace the community house with a 47-story office building. Citing the landmarks law, the city denied the church’s application, stating that the church had failed to prove that the community house was fundamentally unsuitable for its current use. The city indicated it would be open to an application to renovate and expand the community house. The church sued the city, arguing that the landmarks law violated (1) the Free Exercise Clause by substantially burdening the church’s religious activities and (2) the Takings Clause by severely restricting the church’s ability to use its property without just compensation. At trial, the church failed to prove that renovating the community house would fail to address the church’s space concerns or that renovations would be financially impossible. The district court ruled in favor of the city, holding that the church had failed to prove that the community house was fundamentally unsuitable for the church’s present activities. The church appealed.