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Guru Nanak Sikh Society of Yuba City v County of Sutter

    Brief Fact Summary. Guru Nanak is a non-profit organization dedicated to fostering the teachings and practices of the Sikh religion attempted to construct a Sikh temple on its 1.89 acre property in Yuba City.  They first applied for a 1.89 parcel, and the organization then purchases a 28.8 acre lot in an agricultural zoned area that did not border anyone’s front or back yard.  The organization was once again denied.

    Synopsis of Rule of Law.Under RLUIPA  the denial did constitute a “substantial burden”, in violation of RLUIPA.  RLUIPA is Congress’s latest effort to protect the free exercise of religion guaranteed by the First Amendment from governmental regulation- (1) no government shall impose or implement a land use regulation in a manner that imposes a substantial burden on the religious exercise of a person, including a religious assembly or institution, unless the government demonstrates that imposition of the burden on that person, assembly or institution (A) is in furtherance of a compelling governmental interest; and (B) is the least restrictive means of furthering that compelling governmental interest.  42 U.S.C. §2000cc.

    Facts. Guru Nanak is a non-profit organization dedicated to fostering the teachings and practices of the Sikh religion.  In 2001, Guru Nanak attempted to obtain a conditional use permit (“CUP”) for the construction of a Sikh temple on its 1.89 acre property in Yuba City, which was designated for low density residential use (“R-1”).  Churches and temples were only conditionally permitted in R-1 districts through an issuance of a CUP.  They were denied based on citizens’ voiced fears that the resulting noise and traffic would interfere with the existing neighborhood.  The organization then purchases a 28.8 acre lot in an agricultural zoned area that did not border anyone’s front or back yard.  The organization was once again denied based on the “right to farm”.

     

    Issue.  Whether a local government’s denial of a religious group’s application for a conditional use permit to construct a temple on a parcel of land zoned first as “residential” and second as  “agricultural” constituted a “substantial burden” under the Religious Land Use and Institutionalized Persons Act of 2000 (FLUIPA), 42 U.S.C. §§2000cc, et seq… 

     

    Held. The U.S. Court of Appeals affirmed the district court’s order granting summary judgment for Guru Nanak and enjoining the County immediately to approve and grant Guru Nanak’s CUP application.

     

    Discussion. The net effect of the County’s two denials and underlying rationales essentially shrunk the amount of land theoretically available to Guru Nanak which could be approved.  Because the County’s actions had a significantly great extent lessened their prospects the County had imposed a substantial burden on Guru Nanak’s religious exercise.  The County conceded that it had no compelling interest and that the restrictions were not narrowly tailored to accomplish such interest, invalidating the denial of Guru Nanak’s CUP application.

     


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