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World Outreach Conference Center v. City of Chicago and Trinity Evangelical Lutheran Church v. City of Peoria
United States Court of Appeals for the Seventh Circuit
591 F.3d 531 (2009)
World Outreach Conference Center (World Outreach) (plaintiff), a Christian group operating a community center in Chicago, applied for a single-room-occupancy (SRO) license so that World Outreach could pursue its religious mission of providing housing to the homeless and the needy. The City of Chicago (Chicago) (defendant) denied the SRO license, claiming that Word Outreach had to seek a Special Use Permit (SUP) to operate a community center in that district. However, the SRO use was a legal nonconforming use, requiring no SUP. Subsequently, Chicago passed an amendment making the district a limited-manufacturing district for which no SUP could be issued, but the SRO use was still a legal nonconforming use and could be allowed without an SUP. Chicago still denied the SRO license. World Outreach sued, alleging that Chicago’s application of land-use regulations imposed a substantial burden upon World Outreach’s religious exercise in violation of the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C. §§ 2000cc et seq. World Outreach also made claims of religion-based discrimination and equal-protection violation. The district court dismissed World Outreach’s RLUIPA claim on the ground that requiring World Outreach to appeal the denial of an SUP was not a substantial burden, and dismissed the religious-discrimination and equal-protection claims as well. World Outreach appealed to the United States Court of Appeals for the Seventh Circuit. The case was consolidated with a RLUIPA suit by the Trinity Evangelical Lutheran Church (Trinity) (plaintiff), which had sued the City of Peoria (Peoria) (defendant) because Peoria’s designation of Trinity’s church as a landmark prohibited Trinity from demolishing the church and building a family-life center on the site. There was an alternative lot on Trinity’s campus where Trinity could build the center. At oral argument, Peoria committed to granting a permit to build the center on that alternative lot. The district court granted summary judgment to Peoria. Trinity appealed.
Rule of Law
Holding and Reasoning (Posner, J.)
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