Guru Nanak Sikh Society of Yuba City v. County of Sutter Casey Kroon Dennis Nelson Larry Munger Dan Silva

We must decide 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 “agricultural” constituted a “substantial burden” under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C. §§ 2000ce, et seq., and if we find that the denial was a substantial burden, whether RLUIPA is constitutional.

We find that the County imposed a substantial burden on Appellee Guru Nanak Sikh Society of Yuba City’s (“Guru Nanak’s”) religious exercise under RLUI-PA because the stated reasons and history behind the denial at issue, and a previous denial of Guru Nanak’s application to build a temple on a parcel of land zoned “residential,” to a significantly great extent lessened the possibility of Guru Nanak constructing a temple in the future. We also decide that the County did not assert, much less prove, compelling interests for its action; last, we find the relevant portion of RLUIPA is a permissible exercise of Congress’s remedial power under Section Five of the Fourteenth Amendment.

Accordingly, we affirm the district court’s order that granted summary judgment for Guru Nanak,…