## Facts

- Candlehouse, Inc. operated Candlehouse Teen Challenge, a Christian nonprofit residential program for young women struggling with addiction or emotional disorders.
- Candlehouse bought property in the Town of Vestal, New York that had previously been used for church-related purposes, and planned to use the site both as a place of worship and as a dormitory-style residence for about 12 program participants.
- The property was located in a residential zoning district. Under the Town’s zoning code, permitted residential uses were limited (including one-family dwellings and only very small boarding-house-type arrangements), and larger congregate or institutional residential uses were not permitted as-of-right.
- Candlehouse contended that the proposed residents would live together in a stable, structured, “family-like” setting and therefore qualified as the “functional equivalent of a family” under the zoning code’s family definition.
- The Town’s Code Enforcement Officer determined the proposed use did not qualify as the functional equivalent of a family and was not permitted in the residential district.
- Candlehouse appealed to the Town’s Zoning Board of Appeals, which upheld the Code Enforcement Officer’s determination.
- Candlehouse asked the Town to grant a reasonable accommodation under the Fair Housing Act (FHA) and Americans with Disabilities Act (ADA), and asserted that the zoning restriction violated the Religious Land Use and Institutionalized Persons Act (RLUIPA). The Town did not grant the requested relief.
- Candlehouse sued, asserting claims under the FHA, ADA, and RLUIPA. The parties filed cross-motions for summary judgment, and Candlehouse also sought sanctions; the Town offered an expert report that Candlehouse sought to limit or exclude.

## Issues

1. Whether the Town was entitled to summary judgment on Candlehouse’s FHA and ADA disparate-impact claims based on the zoning restrictions applied to Candlehouse’s proposed use.
2. Whether the Town was entitled to summary judgment on Candlehouse’s RLUIPA claim alleging that the Town’s zoning enforcement imposed a substantial burden on Candlehouse’s religious exercise.
3. Whether either party was entitled to summary judgment on Candlehouse’s FHA/ADA intentional-discrimination and reasonable-accommodation claims, or whether material fact disputes required those claims to proceed.
4. Whether sanctions were warranted based on the record presented, and whether portions of the Town’s expert opinions should be excluded from trial.

## Decision

- The court granted summary judgment to the Town dismissing Candlehouse’s disparate-impact claims under the FHA and ADA.
- The court granted summary judgment to the Town dismissing Candlehouse’s RLUIPA claim, concluding the challenged land-use decision did not impose a substantial burden within the meaning of the statute.
- The court denied summary judgment to both sides on Candlehouse’s FHA/ADA intentional-discrimination and reasonable-accommodation claims, finding genuine disputes of material fact.
- The court denied Candlehouse’s sanctions request as not ready for decision on the record at that time.
- The court limited the Town’s expert testimony, precluding the expert from offering certain conclusions at trial.

## Legal Principles

- FHA/ADA disparate-impact liability requires proof that a neutral policy causes a disproportionately adverse effect on a protected group; in housing-and-zoning cases, courts commonly look for quantitative or comparable evidence linking the policy to a group-level housing impact, not just the plaintiff’s difficulties with a single site.
- FHA/ADA intentional-discrimination claims can be proven through direct evidence or circumstantial evidence (including evidence of bias in the sequence of events), but summary judgment is improper when competing inferences about motive and knowledge remain for the factfinder.
- FHA/ADA reasonable accommodation requires a showing that the requested change is needed to provide an equal opportunity for persons with disabilities and is reasonable in light of the municipality’s land-use scheme; whether an accommodation is necessary and reasonable may turn on disputed facts.
- RLUIPA’s substantial-burden provision is not triggered by every denial of a preferred religiously affiliated land use; the burden must be serious enough to pressure the religious actor to change religious conduct or to effectively bar meaningful religious exercise, not merely to make a project more difficult or more expensive.
- On summary judgment, courts do not resolve credibility disputes or choose between competing factual accounts; when the record supports more than one reasonable view on key elements, claims must proceed to trial.

## Conclusion

The court did not accept Candlehouse’s case as a complete win or loss at the summary-judgment stage: it dismissed the FHA/ADA disparate-impact theories and the RLUIPA substantial-burden claim as a matter of law, but held that disputed facts prevented judgment on the FHA/ADA intentional-discrimination and reasonable-accommodation claims, which were left for trial, while also declining to impose sanctions and narrowing parts of the Town’s expert testimony.


Candlehouse, Inc. v. Town of Vestal, 2013 WL 1867114 (2013)