RLUIPA Round Up – Independence Day Special Edition!

Original Photography by dpblrds (license)

Independence Day—no better time to reflect on the numerous (enumerated and unenumerated) rights protected by our United States Constitution. Thanks to Obergefell v. Hodges, those rights are now more clearly focused. However, as reported below, it appears that a battle may be brewing between the right to marriage and religious exercise.  In the spirit of the Fourth of July, RLUIPA Defense salutes our Founding Fathers with another Round-Up!

  • After SCOTUS legalized gay marriage, polygamists Nathan Collier and his wives Victoria and Christine applied for a marriage license in Montana, the Associated Press reports.
  • Texas Attorney General, Ken Paxton, issued an opinion stating that Texas county clerks may refuse to issue same-sex marriage licenses based on their religious beliefs despite the Supreme Court’s ruling in Obergefell v. Hodges.
  • According to the American Civil Liberties Union’s press release, the ACLU of Louisiana filed suit in Louisiana state court challenging Governor Bobby Jindal’s May 19 Marriage and Conscience Order. Jindal’s response is reported by Breitbart.
  • The United States Department of Justice Civil Rights Division issued its June, 2015 edition of “Religious Freedom in Focus,” which includes the following stories:
    • United States’ Suit Alleging Systematic Religious Discrimination by Twin Cities on Utah/Arizona Border May Proceed to Trial, Court Rules
    • DOJ Closes Investigation of Virginia County After Rezoning Allows Church Construction (RLUIPA Defense post, here)
    • Supreme Court Clarifies Religious Accommodation Standard Under Title VII (RLUIPA Defense post, here)
    • Georgia City Changes Zoning Ordinance to Treat Religious and Non-Religious Assemblies Equally (related RULIPA Defense post on Kennesaw, Georgia, here)
    • Florida Must Provide Kosher Meals for Prisoners, Court Rules (RLUIPA Defense post, here)
  • Gawker reports on alleged FOI request-compliance costs in the amount of $79,000 for McKinney, Texas in response to requests for information on the incident where officer Eric Casebolt was filmed pointing his service weapon at unarmed black teenagers at a pool party.
  • The Colorado Supreme Court invalidated Douglas County, Colorado’s school voucher program, which allowed the use of tax-funded vouchers at “23 district-approved ‘private school partners’ — 16 of which were religious,” the New York Times reports.
  • Muslim woman sues after being forced to remove her headscarf at Dearborn police headquarters for a booking photo, Michigan Live
  • The Washington Post reports on the Ninth Circuit Opinion in Jones v. William, which concluded that a prisons “grill cleaning method” did not substantially burden prisoner’s religious beliefs because adequate alternatives to grilled meat were provided.
  • Your Daily Journal reports about a church-run tent ministry, Place of Grace shelter, that is seeking approval for a permanent shelter in Rockingham, North Carolina and may encounter public opposition.

Ten Commandments Monument on Public Grounds Violates Oklahoma Constitution

Original Photography by George Bannister (Licensed)

Original Photography by George Bannister (Licensed)

In a case we have been following, Oklahoma’s Supreme Court has ruled that a Ten Commandments monument on the Oklahoma Capitol grounds is unconstitutional under state law.  We previously reported on the lower court’s decision that the six-foot monument, which was a gift from an Oklahoman, did not violate the state constitution because of its historical value.  Following the Supreme Court’s decision in Prescott v. Oklahoma Capital Preservation Commission, the monument will have to be removed.

In reversing the lower court’s decision, the Supremes rejected the Preservation Commission’s reliance on Van Orden v. Perry, 545 U.S. 677 (2005), a case involving the U.S. Constitution’s Establishment Clause.  The Oklahoma court noted that “the issue in the case at hand is whether the Oklahoma Ten Commandments monument violates the Oklahoma Constitution, not whether it violates the Establishment Clause.” (emphasis in original).

Van Orden involved a Texas Ten Commandments monument placed in a large park containing 17 monuments and 21 historical markers to demonstrate the ideals of those who settled in Texas.  The U.S. Supreme Court found that the monument had “dual significance, partaking of both religion and government.”  The Preservation Commission argued that the Oklahoma monument had some similar historic value.

But the Oklahoma Supreme Court noted that its “opinion rests solely on the Oklahoma Constitution with no regard for federal precedent.”  Article 2, Section 5 of the Oklahoma Constitution states:

No public money or property shall ever be appropriated, applied, donated, or used, directly or indirectly, for the use, benefit or support of any sect, church, denomination, or system of religion, or for the use, benefit, or support of any priest, preacher, minister, or other religious teacher or dignitary, or sectarian institution as such.

Oklahoma’s Supreme Court focused on the use of the word “indirectly” in the state constitution to find the broad and expansive prohibition against using public property to promote religion.

As shown in Prescott, the distinction between state and federal constitutions, although not always obvious, may be substantial.  In light of Prescott, local governments throughout the country may wish to carefully review state constitutions – in addition to federal law – before permitting state or municipal religious displays on public property.

RLUIPA Suit Looms After Controversial Connecticut Church Denial

Original Photography by Don O’Brien (Licensed)

The Danbury Zoning Board of Appeals denied a church’s application for variances to develop an 18-acre parcel with a house of worship and priest residence.  Now, Danbury could join the list of Connecticut municipalities that have faced or are currently facing religious land use lawsuits brought under the Religious Land Use & Institutionalized Persons Act (New Milford, Newtown, Litchfield, Norwalk, Norwich, and Greenwich have all been sued under RLUIPA).*

Church of the Miraculous Medal, Inc. (Church) sought to vary two Danbury zoning regulations: (a) Section 4.A.4.a.(1)’s requirement for vehicular access to a collector or arterial street, and (b) Section 4.A.4.a.(6)’s requirement that a church site have public water and sewer if in a water company watershed.  Long Ridge Neighborhood Preservation Association (Association) raised classic NIMBY concerns – increased traffic and degraded water quality – to oppose the Church’s proposal.

Other opponents objected to the proposal because of ties between the Church’s priest, Gerardo Zendejas, and controversial priest Richard Williamson, who was excommunicated by the Catholic Church and also convicted in a German court for denying the Holocaust.  According to Wikipedia, Mr. Williams stated during a 2008 interview: “I believe that the historical evidence is strongly against, is hugely against six million Jews having been deliberately gassed in gas chambers as a deliberate policy of Adolf Hitler,” and “I think that 200,000 to 300,000 Jews perished in Nazi concentration camps, but none of them in gas chambers.”  Mr. Williamson is a financial backer of the Danbury church.

In response, the Church’s attorney, Thomas Beecher, said there has been an inordinate amount of scrutiny of the Church and its leader, and reminded the ZBA of the protection afforded religious uses under RLUIPA.  But the ZBA did not waiver under the threat of RLUIPA.

The ZBA’s denial comes after months of debate.  Ultimately, the ZBA determined that the Church had not established unique hardship sufficient to justify the granting of the variances.  The ZBA’s resolution stated in part: “The claim of hardship is self-imposed and based on the applicant’s personal preferences for how they wish to use the property.”  The resolution adds that: “There is substantial evidence in the record that allowing the church on Long Ridge Road … would adversely affect the public health and safety.”

It is important to note that one of the factors used by courts to analyze a possible violation of RLUIPA’s substantial burden provision is whether a zoning agency’s decision is supported by substantial evidence in the record or if it is instead arbitrary and capricious.  The Second Circuit, in Chabad Lubavitch of Litchfield County, Inc. v. Borough of Litchfield (2d Cir. 2014) (see prior post here), noted several other factors considered by the courts:

  • Whether the denial is absolute or if it leaves open the possibility to develop the property for religious use in some other way
  • Whether the religious applicant had a “reasonable expectation” of receiving approval
  • Whether feasible alternative sites are available to the religious applicant
  • Whether the proposed use is necessary for religious exercise or is a matter of personal preference

Religious discrimination, explicit or implicit, may also support a RLUIPA violation.  At this time, it is not clear whether the Church will challenge the ZBA’s denial.

*Robinson & Cole LLP is involved in the Norwich lawsuit – St. Vincent de Paul Place, Norwich, Inc. v. City of Norwich.

Guest Commentary: Life after Reed v. Gilbert

Last week, we reported on the potential impact of Reed v. Gilbert, the sign regulation case that has municipalities across the nation concerned about the enforceability of local sign ordinances. This week, we’re happy to provide the guest commentary of Brian J. Connolly,[*] a regular contributor to Rocky Mountain Real Estate Law Blog, who reported on the Reed case here. Brian’s observations about the case include:

  • While Justice Alito’s concurrence suggests several potential avenues of sign regulation that he believes are content neutral, it is unclear whether the authors of the majority opinion (and even the Breyer and Kagan concurrences) agree, and it may therefore be difficult for a local government lawyer to defend, say, a distinction between onsite and offsite signage, or a temporary event sign regulation, before a lower federal court or a state court.
  • The majority opinion does not cite to any of the majority opinions in the abortion clinic cases (including last term’s decision in McCullen v. Coakley, where Chief Justice Roberts espoused a different view of content neutrality than the Court adopted in Reed), nor does it cite to some standard sign law precedents such as Metromedia and Ladue. (See RLUIPA Defense’s report on McCullen v. Coakley here.) The “secondary effects” cases relating to the regulation of adult business also go unmentioned. I do not believe the Court was trying to sneakily overrule any of these cases, but it’s tough to square the Reed majority opinion with some of the holdings in these prior cases, and it remains to be seen whether Reed was truly intended to cut back at any of these earlier decisions.
  • The Reed decision does not mention the distinction between noncommercial and commercial speech. Older cases, including Metromedia, held that commercial speech gets less First Amendment protection than noncommercial speech. In the 30-plus years since Metromedia, however, commercial speech has received increasing protection. The 2011 case of Sorrell v. IMS Health reviewed commercial speech regulations under a time, place, and manner noncommercial speech analysis. Does all of this mean that the commercial speech doctrine is dead? Probably not. But one has to question whether the Court’s approach in Reed, the heavy citation to Sorrell in the Reed majority, and failure to mention the commercial speech doctrine suggests a gradual phasing-out or weakening of the commercial speech doctrine.
  • With this decision, local governments need to be thinking about updating their sign codes now instead of waiting for a legal challenge to force the update. While all hope is not lost—local governments will still be able to regulate signs, and there are very clearly content neutral approaches that will work post-Reed—the outcome of this case certainly represents a challenge to “business as usual” in sign regulation. Moreover, because the overbreadth doctrine opens doors for broad challenges to sign codes, and indeed, sign owners and others will be looking at sign codes nationwide to identify possible challenges, local governments should get ahead of the game to draft their sign codes in ways to comport as closely as possible to Reed’s Many local sign codes contain questionably content-based distinctions, so local governments would be wise to consult lawyers familiar with First Amendment sign regulation law as they consider how to approach updates to their regulations.

To learn more about Reed v. Town of Gilbert and how it impacts local governments, landowners and other sign owners, tune in to one of two upcoming webinars on the case, each of which will include some of the nation’s leading thinkers and practitioners on First Amendment and sign regulation issues.

  • On July 16 at 1:00 p.m. EST, the American Bar Association Section of State and Local Government will host a webinar discussing the impact of Reed for lawyers who practice in First Amendment-related areas of law.
  • On July 21 at 1:00 p.m. EST, the Planning and Law Division of the American Planning Association will host a webinar discussing how Reed will affect planners and local governments.

Registration for both events is expected to open shortly, so be sure to check out the web pages of each of these groups.

[*] This is a guest commentary from Brian J. Connolly of Otten, Johnson, Robinson, Neff + Ragonetti who is not affiliated with Robinson + Cole, LLP, and RLUIPA-Defense.com is not responsible for the content of this post.

RLUIPA Round-Up

Below are news items from the past week involving local government, religion, and land use that have caught our attention.

  • Coral Springs, Florida may allow Satanist Chaz Stevens to begin a City Commission meeting with an invocation honoring Satan in September or October. However, Mayor Skip Campbell will first meet with commission members to discuss invocation procedures (Coral Springs Talk has more). Last year, we noted that following the Supreme Court’s decision in Town of Greece v. Galloway, Mr. Stevens, who recently converted to Pabstfestidian because “Satan is a cool dude,” requested that the City of Deerfield Beach, Florida allow him to begin a town council meeting with an invocation to honor Satan – his “Dude in Charge” (prior post here).
  • CBN News reports that there have been acts of anti-Semitism and vandalism in the area of Toras Chaim synagogue, which has countersued the City of Dallas, Texas under RLUIPA contending that the City’s efforts to close the synagogue for failure to renovate the subject property and obtain a certificate of occupancy violate the statute (see our prior post here).
  • Randall Daluz, convicted of triple murder, may bring a RLUIPA and First Amendment suit to challenge the Maine Department of Corrections’ policy prohibiting prisoners from publishing their work. With the assistance of his spiritual advisor’s wife, Mr. Daluz started a website – The Journal of a New Creation – to spread his Christian beliefs. Mr. Daluz handwrites his religious messages that are then transcribed onto the website by the spiritual advisor’s wife (Governing reports on the story). Follow the hyperlink to access The Journal of a New Creation
  • Religion Clause reports that the Ninth Circuit has rejected an Aryan Christian Odinist prisoner’s claim that having a non-white cellmate violates RLUIPA’s substantial burden provision. The prisoner claimed that the presence of a non-white cellmate would pollute his Odinist religious practice known as “the spiritual circle of Odinist Warding.” The Ninth Circuit’s decision in Walker v. Beard, No. 12-17460 (9th Cir. 2015), is available here.
  • The Washington Post reports that the American Civil Liberties Union no longer supports the Religious Freedom Restoration Act because, following the Supreme Court’s decision in Burwell v. Hobby Lobby Stores, Inc., the Act is being used as a tool to discriminate or impose one’s views on others.
  • MLive reports that Flint, Michigan City Attorney Peter Bade issued a June 22 opinion advising the City Council that invocation can be allowed in meetings, but suggested that council members not lead the invocation. Hours later, Councilwoman Jackie Poplar led an pre-meeting invocation and stated that the City Attorney’s opinion was “poppycock.”
  • Forsythe County News reports of the ongoing saga of Chinmaya’s proposed Hindu temple in west Forsythe opposed by a homeowners’ association. The proposal will consist of about 60,000 square feet and include more than 300 parking spaces.

IMLA Webinar Recap: How to Avoid and Defend RLUIPA Suits

On June 8, 2015, I participated in a webinar hosted by the International Municipal Lawyers Association with co-blogger Karla Chaffee and Michael Giaimo of Robinson & Cole. If Mike’s name sounds familiar, it should – he is the co-editor of The RLUIPA Reader; Religious Land Use, Zoning, and the Courts, and he filed an amicus curiae brief on behalf of the American Planning Association in this important Ninth Circuit decision.

Mike, Karla, and I discussed the different approaches developed by the courts to address substantial burden and equal terms claims brought under the Religious Land Use and Institutionalized Persons Act (RLUIPA). One recent development that was discussed was the Seventh Circuit’s decision in Schlemm v. Wall (7th Cir. 2015) – a prisoner case – and how that case may change the Seventh Circuit’s analysis of substantial claims (see our prior post about Schlemm here). We also discussed how the Supreme Court’s decisions in Burwell v. Hobby Lobby Stores, Inc. and Holt v. Hobbs are being relied on by more and more plaintiffs in RLUIPA suits. One example of this that we examined is in the  pending Ninth Circuit case Harbor Missionary Church v. City of San Buenaventura, California (see our prior post about this case here).

We also discussed preemptive action that local governments may wish to consider to avoid facial challenges to zoning codes:

  • planning for religious uses by creating a surplus of land for religious use
  • reviewing zoning codes to ensure that religious uses are treated no worse than other secular assembly uses
  • providing compelling interests in the code itself to justify any differential treatment

To avoid and defend as-applied challenges under RLUIPA, we noted the importance of (1) understanding the religious needs of the applicant; (2) whether there are any alternatives available to the applicant; (3) whether similar religious or secular assembly uses have been allowed in the jurisdiction; and (4) whether a local decision truly hinders the religious applicant’s ability to exercise its religion or if it is instead a matter of personal preference or convenience for the applicant.

Click the following hyperlinks to see the Resource List and the Case Digest provided for the webinar.  The Powerpoint is available here.

Reed v. Gilbert: Impact to municipalities across the nation

Although the case is outside the RLUIPA realm or even specific to religious-based speech, the Supreme Court’s decision last week in Reed v. Gilbert will undoubtedly impact RLUIPA Defense readers. We previously reported on the January 12 oral argument (here) and the Court’s grant of certiorari (here).

Why is Reed v. Gilbert important for municipalities? Putting aside SCOTUSblog’s observance that after Reed and Walker v. Texas Division, Sons of Confederate Veterans (post coming soon) “the meaning of the First Amendment, in general, became somewhat more confusing,” Reed has clearly changed how courts will view content neutrality. Further, Reed makes clear that view-point neutral regulation is not synonymous with content-neutral regulation.

Our previous posts provide a more complete overview of the facts of the case. Briefly, Good News Community Church (Good News) claimed that Gilbert’s sign ordinance made impermissible content-based distinctions between “Temporary Directional Signs, Ideological Signs, and Political Signs.”   Good News, which holds services at different locations from week to week, used signs directing congregants to each week’s chosen location. Gilbert categorized such signs as “Temporary Directional.” The Ninth Circuit disagreed with Good News, finding that the sign restrictions, including the distinctions among them, were content-neutral for purposes of free speech:

[T]he distinction between Temporary Directional Signs, Ideological Signs, and Political Signs are content-neutral. That is to say, each classification and its restrictions are based on objective factors relevant to Gilbert’s creation of the specific exemption from the permit requirement and do not otherwise consider the substance of the sign. . . . It makes no difference which candidate is supported, who sponsors the event, or what ideological perspective is asserted. Accordingly, as the speaker and event determinations are generally “content-neutral,” Gilbert’s different exemptions for different types of noncommercial speech are not prohibited by the Constitution.

The Supreme Court disagreed. The Court’s majority opinion, authored by Justice Thomas, started with the well-recognized principle: “Content-based laws—those that target speech based on its communicative content—are presumptively unconstitutional and maybe justified only if the government proves that they are narrowly tailored to serve compelling state interests.”

The Court found that the ordinance is “content based on its face.” According to the Court, the ordinance regulates based on the message conveyed: Temporary Directional signs convey a message directing the public; Political Signs are designed to influence the outcome of an election; and Ideological Signs communicate a message or idea. By regulating the message, Gilbert regulated the “communicative content of the sign,” making the ordinance content based and subject to strict scrutiny review. Even though the ordinance may have a content-neutral justification, “[i]nnocent motives do not eliminate the danger of censorship presented by a facially content-based statute, as future government officials may one day wield such statutes to suppress disfavored speech.”

The Court went on to conclude that Gilbert’s purported reasons for the regulation, preserving the Town’s aesthetic appeal and traffic safety, were not adequate justifications to pass strict scrutiny review. Assuming the these interests were “compelling,” the Court found the ordinance “hopelessly underinclusive” because the same restrictions were not placed on other types of signs. Thus, Gilbert failed to show that its ordinance was “narrowly tailored to further a compelling government interest.”

The Court concluded the majority opinion by noting that its decision does not limit a municipality’s ability to regulate signage, so long as the regulation is content neutral. For instance, “size, building materials, lighting, moving parts, and portability” may be regulated without reference to a sign’s message. Further, “on public property, the Town may go a long way toward entirely forbidding the posting of signs, so long as it does so in an evenhanded, content-neutral manner.”

Although the decision was unanimous, the Justices filed three separate concurring opinions. Justice Alito, joined by Justices Kennedy and Sotomayor added “a few words of further explanation.” Justice Alito stressed that municipalities are not powerless to enact sign regulation, and provided a non-inclusive list of content neutral criteria:

  • Rules regulating the locations in which signs may be placed;
  • Rules distinguishing between lighted and unlighted signs;
  • Rules distinguishing between signs with fixed messages and electronic signs with messages that change’
  • Rules that distinguish between the placement of signs on private and public property;
  • Rules distinguishing between the placement of signs on commercial and residential property;
  • Rules distinguishing between on-premises and off-premises signs;
  • Rules restricting the total number of signs allowed per mile of roadway; and
  • Rules imposing time restrictions on signs advertising a one-time event.

Justice Breyer provided a separate opinion urging that content-based discrimination “cannot and should not always trigger strict scrutiny.” (emphasis in original) Justice Breyer recognized that “[r]egulatory programs almost always require content discrimination” and provided several examples of content-based regulation where “a strong presumption against constitutionality has no place.”

Finally, Justice Kagan, joined by Justices Ginsburg and Breyer, provided a third concurrence. Justice Kagan, like Justice Breyer, questioned the reasonableness of applying strict scrutiny review to all types of content-based regulation:

“We can administer our content-regulation doctrine with a dose of common sense, so as to leave standing laws that in no way implicate its intended function.”

Concurring only in the judgment, Justice Kagan prophesized that courts will now be required to invalidate numerous “entirely reasonable” sign ordinances, making the Court “a veritable Supreme Board of Sign Review.”

 

RLUIPA Round-Up

We’re a little late with the round-up this week, but promise to continue our effort to bring you interesting stories from the intersection of religion and government.

  • Mayfair, Pennsylvania residents feel disappointment after renovated, historic theater fails to bring live entertainment to downtown, but will likely house Kingdom Life Christian Center, philly.com reports.
  • Objections from Islamic leaders continued in the run up to World Yoga Day on June 21, according to Mumbai’s dna.
  • According to the Global Dispatch, “the Freedom From Religion Foundation has sent letters to every member of the New York Assembly urging them to take a strong stand against private tax credit bills that ‘subsidize religiously-segregated schools.’”
  • New Jersey’s Supreme Court has ruled that municipal officials cannot vote on a zoning application for land within 200 feet of the church where they are members, the Montclair Patch reports.
  • Crawford County, Kansas and Liberty Baptist Church settle RLUIPA claims. The church agrees to add screening while the County covers some of the church’s fees, the Morning Sun reports.
  • A former Delaware State University volleyball player sues the university, claiming her former coach compelled attendance at coach’s church Sunday services, the Associated Press and ABC News reports.
  • New York Sikh student wins the right to join his college’s ROTC program without shaving his religious beard or removing his religious turban, according to Niti Central.
  • Freedom From Religion Foundation objects to sheriff delivering a church sermon while in uniform, Bay News 9 reports.

Court Order Cuts Attorneys’ Fees in Jacksonville Beach Case

Earlier this year, we reported that the dispute between Jacksonville Beach, Florida and the Church of Our Savior continued to boil in mediation, with attorneys’ fees nearing $700K. After finding that Jacksonville violated RLUIPA’s equal terms provision and that the city should have issued a conditional use permit (CUP), the Middle District Court of Florida ordered that the parties meet and discuss what “reasonable” conditions might be appropriate in the Church’s CUP.

In February, the parties’ discussions reportedly reached an impasse. In March, the City Council issued a CUP to Our Savior, which included several provisions that the Church found unacceptable. Law of the Land reports that last month, the court considered the various remaining issues between the parties:

On April 10, 2015, the Court conducted a hearing on three issues: the City’s motion for reconsideration of the Court’s original ruling finding the City to be in violation of the Equal Terms provision of RLUIPA, the Church’s objections to some of the conditions imposed by the City on the CUP, and the Church’s motion for attorneys’ fees and costs.

The motion of reconsideration was denied by the court since the City acknowledged there was no newly-discovered evidence and pointed to no intervening change in controlling law ….

As to the objections to the CUP, however, the court found some of the Church’s objections to have merit. The court agreed that there should be no provision prohibiting future variance applications, nor a condition mandating the Church to secure development plan approval of its proposed facilities “within twelve months of issuance of the conditional use permit …” Other conditions, such as imposing a pedestrian only easement, and requiring the erection of a fence, were permitted.

The Church sought $851,352.59 in attorney’s fees and costs…. the court found the amount of hours and fees charged to be excessive of the median, and therefore found that an across-the-board reduction of 50% appropriately accounted for all of the factors the Court has considered in this Order. Consequently, the Court awarded $281,535.68 in fees and $23,612.08 in expenses, for a total of $305,147.76.

The court’s final judgment is available here and the court’s order and opinion is available here. Our December, 2014 post, provides a detailed discussion of the case facts and all RLUIPA claims considered by the court. As we then noted, this case is important because it provides guidance on what it means to be a “similarly situated” comparator under RLUIPA’s equal terms provision.

RLUIPA Round-Up

We bring you more interesting news from the world of land use, religion and government:

  • The Chicago Tribune reports that the Village of La Grange, Illinois Planning Commission is considering a proposed zoning code amendment that “would require churches to obtain a special use permit for certain activities, including scouting groups, not deemed part of the congregation’s mission.” Many in the religious community provided strong opposition, while some residents requested more oversight of activities such as homeless assistance programs.
  • Freedom From Religion Foundation (FFRF) provided a letter to Washington Island, Wisconsin requesting that the municipality no longer erect a large cross for Easter sunrise service at Door County’s Percy Johnson Memorial Park. The Green Bay Press Gazette
  • Religious Clause posts on a Wall Street Journal story about Muslim leaders in India who object to requiring students to learn yoga, including “surya namaskar,” the sun salutation.
  • Thanks again to Religious Clause: Freedom From Religion Foundation (FFRF) objects to a large sign apparently put up by the city of Hawkins, Texas on City land reading “Jesus Welcomes You To Hawkins.”
  • The Sun Journal reports that at a recent Planning Board meeting, Oxford Hill, Maine residents objected to CityReach Oxford Hills establishing a long-term faith-based recovery program for addicts.
  • The organization “Protect Wine Country” and advocates for Calvary Chapel disagree over whether the Riverside County Board of Supervisors should repeal an ordinance places time limits on the operation of non-conforming uses, including churches, the Press-Enterprise
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