Today we report on a fascinating decision out of the Tenth Circuit.  It’s not a land use case.  It’s not even an RLUIPA case.  But we thought it appropriate for this time of year.  The plaintiff, a pro se prisoner named Muamar Sayyed, claims to be the “Spirit of God and Son of Man, the second coming of Jesus Christ and the Messiah for which the Bible instructs Christians to watch.”  According to Mr. Sayyed, he has evidence that he is the Messiah.  For example, he says that if you attribute numbers to the letters in the word “Jesus,” based on where the letters fall in the alphabet, and then add those numbers together, it equals 74.  According to Mr. Sayyed, if you do the same with respect to “Moammar,” a variation of his first name, you also get 74.

Mr. Sayyed sued several churches on a claim for “Contracts, Agreement not honored by Defendants.”  Mr. Sayyed believes that he, as the self-proclaimed Son of God, and the churches had a binding contract in the form of the Bible.  He sent the churches three letters and “invitations asking, explaining, advising, ordering and demanding that they abide by clear and explicit agreements and contracts set forth in the Bible.”  Mr. Sayyed believes that the churches “preach and agree, know and understand, desire and have a deep committment [sic] in honor and filfilling [sic] these agreements, yet they had failed to do so.”  The Tenth Circuit found Mr. Sayyed’s claims to be both legally and factually frivolous, because Mr. Sayyed’s belief that he is the Messiah depicts a “fantastic or delusional scenario[].”

What is of interest in this decision?  It exemplifies the limits to religious protection.  While the courts generally do not second guess a religious land use applicant’s religious beliefs, they may if those beliefs are posited only to defeat zoning requirements.  Take, for example, the 2006 story of Georgetown University fraternity brothers who incorporated as a religious organization (the Apostles of Peace and Unity) in an attempt to beat back the zoning code’s prohibition on six unrelated persons living together (more on that story here).  The decision in Sayyed v. Six Churches is available here.