Civil Liberties for Urban Believers v. City of Chicago
United States Court of Appeals for the Seventh Circuit
342 F.3d 752 (2003)
Chicago's zoning ordinance (CZO) permitted churches as of right in residential zones but required a roughly $5,000 special-use permit process in commercial and business zones, and rezoning in manufacturing or some commercial zones; the city later extended the same special-use requirement to clubs, lodges, meeting halls, and community centers wherever churches needed one. A coalition of religious organizations (plaintiffs) challenged the CZO under RLUIPA, the Free Exercise Clause, and Equal Protection; the trial court granted the city summary judgment on all counts, finding no substantial burden and a neutral, generally applicable law rationally related to a legitimate purpose.
Whether, under RLUIPA, land-use regulation that substantially burdens religious exercise is regulation that makes religious exercise effectively impracticable; whether a law that burdens religious exercise but is neutral, generally applicable, and otherwise valid must be justified by a compelling state interest; and whether strict scrutiny under the Equal Protection Clause applies to laws that gravely interfere with important religious beliefs or compel individuals to act in ways undeniably at odds with those beliefs.