Can the operation of a homeless shelter constitute a church use under local zoning regulations? A court in the Horse Capital of the World, Lexington, Kentucky, will soon be answering that question.

Heres the story. Back in 2010, Breakthrough Ministries obtained a conditional use permit to operate a small church with a sanctuary capable of seating 30 people for services twice per week in an area zoned B-4 (wholesale and warehouse use). Soon after, Breakthrough Ministries vacated the property and the new owners, Emmanuel Apostolic Church Action Center, opened a homeless shelter known as the Community Inn on the property. Since then, the Community Inn has provided housing to as many as 75 homeless people each night from 7:00 p.m. to 8:00 a.m., more than twice the number of people and more than three times as often as had been permitted for church use. In addition to providing shelter for the homeless, the Community Inn provides Bible courses during the week and traditional religious services on Saturday mornings.

Reports of loitering, panhandling, and urinating in the streets among those waiting in line for nightly shelter, however, have cast the Community Inn in an unholy light in the eyes of those in the community. Opponents argue that the Community Inn is in violation of the conditional use permit, allowing a church, not a homeless shelter. A May 11, 2012 Planning Commission Staff Report reached the same conclusion and recommended that the permit be revoked. The report states that ” [t]he outcome of this matter will have a significant impact on zoning interpretation as to what constitutes a church and will also impact how houses of worship may seek conditional use approval in the future.”

The Community Inn maintains that its operation of the shelter is a form of church use. Elder James McDonald, minister of Emmanuel Apostolic Church, stated: “The problem is we have a different idea of what a church really is. The Community Inn, McDonald added, is not a church as society sees it. . . . [but] the presence of the Lord is in this place. A lot of people have been set free of drugs. “

Lexingtons Board of Adjustment saw things differently and, on June 8, voted 5-0 to revoke the permit. The Board, however, gave the Community Inn six months to find a new location.

Rather than search for a new location, the Community Inn filed a lawsuit, alleging that the Citys revocation of the conditional use permit was improper because its operation of the homeless shelter was valid as a church use under the zoning regulations (Click Here to read the Complaint). Under the regulations, the B-4 zone allows as a conditional use: “Churches, Sunday schools, and church-related schools for academic instruction . . . . “

Interestingly, the Community Inn challenges the Boards relocation as a violation of the First Amendment, and not as a violation of RLUIPA. If the Community Inn sued under RLUIPA, such a claim would likely hinge on whether the operation of the shelter was a form of religious exercise, which RLUIPA defines as any exercise of religion, whether or not compelled by, or central to, a system of religious belief. It further provides that [t]he use, building, or conversion of real property for the purpose of religious exercise shall be considered to be religious exercise of the person or entity that uses or intends to use the property for that purpose. As one court recently found: ” [s]imply calling ones practice religious exercise does not make those practices part of the religion.” Moore-King v. County of Chesterfield. In that case, the court determined that, based on the particular facts of the case, fortune-telling did not constitute religious exercise under RLUIPA.

Some courts have already considered whether the operation of a homeless shelter amounts to religious exercise. For example, a court in Florida found that although running a homeless shelter may have been a deeply-held religious belief, under the specific facts before it, the church failed to prove that operating the shelter at that particular location was fundamental to its religious exercise. Westgate Tabernacle, Inc. v. Palmer Beach County. In another case, a federal court in Illinois found that even though providing shelter to the homeless is an essential religious exercise of the church, requiring the church to obtain a conditional use permit to operate a homeless shelter did not substantially burden the churchs religious exercise. Family Life Church v. City of Elgin. The court found that “[p]roviding shelter to the homeless is an essential religious exercise of the members of Family Life.”

While it is unclear if those decisions may serve as guidance for Kentuckys state court, questions as to what constitutes church use under zoning regulations or religious exercise under RLUIPA have far-reaching implications for municipalities and religious organizations. We will keep a close watch on what develops in the case of the Community Inn and the “Horse Capital of the World.”

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Photo of Evan Seeman Evan Seeman

Evan J. Seeman is a lawyer in Robinson+Cole’s Hartford office and focuses his practice on land use, real estate, environmental, and regulatory matters, representing local governments, developers and advocacy groups. He has spoken and written about RLUIPA, and was a lead author of…

Evan J. Seeman is a lawyer in Robinson+Cole’s Hartford office and focuses his practice on land use, real estate, environmental, and regulatory matters, representing local governments, developers and advocacy groups. He has spoken and written about RLUIPA, and was a lead author of an amicus curiae brief at the petition stage before the United States Supreme Court in a RLUIPA case entitled City of San Leandro v. International Church of the Foursquare Gospel.

Evan serves as the Secretary/Treasurer of the APA’s Planning & Law Division. He also serves as the Chair of the Planning & Zoning Section of the Connecticut Bar Association’s Young Lawyers Section, and is the former Co-Chair of its Municipal Law Section. He has been named to the Connecticut Super Lawyers® list as a Rising Star in the area of Land Use Law for 2013 and 2014. He received his B.A. in political science and Russian studies (with honors) from Trinity College in Hartford, Connecticut, where he was selected as the President’s Fellow in the Department of Modern Languages and Literature. Evan received his Juris Doctor at the University of Connecticut School of Law, where he served on the Connecticut Law Review. While in law school, he interned with the Connecticut Office of the Attorney General in the environmental department, and served as a judicial intern for the judges of the Mashantucket Pequot Tribal Court. Following law school, Evan clerked for the Honorable F. Herbert Gruendel of the Connecticut Appellate Court.

Photo of Dwight Merriam Dwight Merriam

Dwight H. Merriam founded Robinson+Cole’s Land Use Group in 1978. He represents land owners, developers, governments and individuals in land use matters, with a focus on defending governments in RLUIPA cases. Dwight is a Fellow and Past President of the American Institute of…

Dwight H. Merriam founded Robinson+Cole’s Land Use Group in 1978. He represents land owners, developers, governments and individuals in land use matters, with a focus on defending governments in RLUIPA cases. Dwight is a Fellow and Past President of the American Institute of Certified Planners, a former Director of the American Planning Association (APA), a former chair of APA’s Planning and Law Division, Immediate Past Chair of the American Bar Association’s Section of State and Local Government Law, Chair of the Institute of Local Government Studies at the Center for American and International Law, a Fellow of the Royal Institution of Chartered Surveyors, a Fellow of the American Bar Foundation, a member of the Rocky Mountain Land Use Institute National Advisory Board, a Fellow of the Connecticut Bar Foundation, a Counselor of Real Estate, a member of the Anglo-American Real Property Institute, and a Fellow of the American College of Real Estate Lawyers.

He teaches land use law at the University of Connecticut School of Law and at Vermont Law School and has published over 200 articles and eight books, including Inclusionary Zoning Moves Downtown, The Takings Issue, The Complete Guide to Zoning, and Eminent Domain Use and Abuse: Kelo in Context. He is the senior co-author of the leading casebook on land use law, Planning and Control of Land Development (Eighth Edition). Dwight has written and spoken widely on how to avoid RLUIPA claims and how to successfully defend against them in court. He is currently writing a book on the subject, RLUIPA DEFENSE, for the American Bar Association.

Dwight has been named to the Connecticut Super Lawyers® list in the area of Land Use Law since 2006, is one of the Top 50 Connecticut Super Lawyers in Connecticut, and is one of the Top 100 New England Super Lawyers (Super Lawyers is a registered trademark of Key Professional Media, Inc.). He received his B.A. (cum laude) from the University of Massachusetts, his Masters of Regional Planning from the University of North Carolina, where he was the graduation speaker in 2011, and his J.D. from Yale. He is a featured speaker at many land use seminars, and presents monthly audio land use seminars for the International Municipal Lawyers Association. Dwight has been cited in the national press from The New York Times to People magazine and has appeared on NBC’s The Today Show, MSNBC and public television.

Dwight also had a career in the Navy, serving for three tours in Vietnam aboard ship, then returning to be the Senior Advisor of the Naval ROTC Unit at the University of North Carolina in Chapel Hill where he taught Defense Administration and Military Management as an Assistant Professor in the undergraduate and graduate curriculum in Defense Administration and Military Management. He left active duty after seven years to attend law school, but continued on for 24 more years as a reserve Surface Warfare Officer with two major commands, including that of the reserve commanding officer of the Naval Undersea Warfare Center. He retired as a Captain in 2009 after 31 years of service.