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Westchester Day School v. Village of Mamaroneck

United States Court of Appeals for the Second Circuit
504 F.3d 338 (2d Cir. 2007)


Facts

Westchester Day School (WDS) (plaintiff), an Orthodox Jewish school, had run out of room in its building so it applied to the Village of Mamaroneck (Village) (defendant) for a permit to construct an expansion. The Village zoning board denied the application, citing traffic and parking concerns. WDS brought suit in federal court, claiming a violation of the Religious Land Use and Institutionalized Person Act (Act), which prohibited the government from imposing a land use regulation in a manner that substantially burdened religious exercise unless the regulation furthered a compelling government interest and was the least restrictive means of furthering that interest. The district court found that the Village’s denial of the application was arbitrary and capricious because the reasoning was not substantially related to the public health, safety, or welfare and the findings were not supported by the substantial evidence. The Village appealed.

Rule of Law

Issue

Holding and Reasoning (Cardamone, J.)

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