Original Photography by Kevin Dooley (Some Rights Reserved)
Original Photography by Kevin Dooley (Some Rights Reserved)

Two Houston churches are using the Texas Religious Freedom Restoration Act (“TRFRA”) to challenge the Houston Housing Authority’s actions to acquire their properties by eminent domain as part of an urban renewal project.  The Latter Day Deliverance Revival Center (“Center”) and the Christian Fellowship Missionary Baptist Church (“Fellowship”) are both located in Houston’s Fifth Ward neighborhood, which is known for a history of violence and crime, and has been called the “bloody Fifth.”  The Housing Authority began eminent domain proceedings against the Center, but there is some dispute as to whether it has started the same action against the Fellowship.  The Housing Authority is taking the private property owned by the Center across the street from the Center’s house of worship.  The Center claims in the lawsuit that it uses this land for ministry activities, including youth centers, food pantries, and providing education and assistance to the community.

The Center asserts that the Housing Authority “wants to steal these churches, bulldoze them and use them for a parking lot for a doctor’s office.”  The Housing Authority contests this characterization, noting that it “had not begun any eminent domain process against any church building” and added that it had only sought to acquire two vacant parcels owned by the churches.  It maintains that it is not going to develop a parking lot for a doctor’s office, but instead for an affordable housing project.

It is noteworthy that the churches are using the state RFRA to challenge the eminent domain proceedings, but not surprising given how courts have resolved Religious Land Use & Institutionalized Persons Act (“RLUIPA”) challenges to eminent domain actions.  Most courts have ruled that RLUIPA does not apply to eminent domain proceedings.  RLUIPA’s substantial burden provision applies to any “land use regulation,” which the Act defines as “a zoning or landmarking law, or the application of such a law, that limits or restricts a claimant’s use or development of land (including a structure affixed to land), if the claimant has an ownership, leasehold, easement, servitude, or other property interest in the regulated land or a contract or option to acquire such an interest.”  Courts have generally ruled that an eminent domain action is not a “land use regulation” as defined by the Act.  See St. John’s United Church of Christ v. City of Chicago (7th Cir. 2007) (“if Congress had wanted to include eminent domain within RLUIPA, it would have said something.”); Congregation Adas Yerim v. City of New York (E.D.N.Y. Dec. 8, 2009) (eminent domain is not a “land use regulation” under RLUIPA); but see Cottonwood Christian Center v. Cypress Redevelopment Agency (C.D. Cal. 2002) (rejecting city’s argument that eminent domain is not a “land use regulation” under RLUIPA).

Unlike RLUIPA, the TRFRA is not limited to land use regulations, but mirrors the federal Religious Freedom Restoration Act and applies to any law or action.  If the churches are successful in convincing the court that the TRFRA should apply in an eminent domain action, it would mean that the Housing Authority would not only have to justify taking the churches’ properties as a “public use,” but would also have to establish that their actions are “compelling interests” advanced in the “least restrictive means” possible, so long as the churches show substantial burdens on their religious exercise.  No local government wants to be in this position.

President and CEO of the Housing Authority Tory Gunsolley stated that without these properties, its redevelopment plan may have to be abandoned:

The sad thing is, if the outcome is, they win, then I think that block is going to stay decrepit for the foreseeable future.  [The churches] haven’t made any progress on executing a vision on redeveloping that block.  Most of the houses are in extreme disrepair.  It needs help and it needs investment, and we are trying to invest in that community.

The Daily Signal reports on this matter.

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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.