## Facts

- Episcopal Student Foundation (Canterbury House) operated a student-focused Episcopal worship and ministry center at 721 W. Huron Street in Ann Arbor’s Old Fourth Ward Historic District.
- The organization conducted religious worship and community ministry at the site, including a weekly “Jazz Mass,” prayer and study groups, and outreach events.
- Canterbury House asserted that its congregation and programming had grown and that the existing building was inadequate, citing limited worship space and kitchen/dining facilities affecting meal-related ministry.
- To address space and functional needs, Canterbury House sought to demolish the existing two-story structure and construct a larger facility.
- The Ann Arbor Historic District Commission denied the demolition permit, finding the building was in good repair and that demolition and replacement would significantly alter the district’s historic character.
- Administrative review affirmed the denial by the Michigan State Historic Preservation Review Board.
- Canterbury House sued under 42 U.S.C. § 1983, principally alleging that the permit denial imposed a substantial burden on religious exercise in violation of RLUIPA’s land-use provisions.
- Both sides moved for summary judgment; the case proceeded on the RLUIPA claim after separate constitutional claims were dismissed.

## Issues

1. Whether denial of a demolition permit for a religious ministry facility in a historic district imposed a “substantial burden” on religious exercise under RLUIPA.
2. If a substantial burden existed, whether RLUIPA was constitutional as applied in this context (raised but not reached).

## Decision

- The court granted defendants’ motion for summary judgment and denied plaintiff’s motion for summary judgment.
- The court held that the demolition-permit denial did not impose a substantial burden on Canterbury House’s religious exercise under RLUIPA.
- Because no substantial burden was shown, the court did not decide defendants’ constitutional challenge to RLUIPA.

## Legal Principles

- Under RLUIPA, a “substantial burden” requires more than inconvenience, increased cost, or reduced efficiency; it involves coercion or governmental pressure so severe that it effectively compels abandonment of religious beliefs or practices or makes religious exercise impracticable.
- A land-use decision does not substantially burden religious exercise where the institution can continue its core worship and ministry activities, even if it cannot do so in its preferred or most effective facility.
- The availability of reasonable alternatives (e.g., reconfiguration, renovation not requiring demolition, or use of alternative venues for some activities) weighs against finding a substantial burden.
- Neutral application of generally applicable historic-preservation criteria, without evidence of religious targeting or hostility, supports the conclusion that the regulation does not impose a substantial burden within RLUIPA’s meaning.
- RLUIPA does not require municipalities to provide maximum accommodation or to allow demolition and rebuilding simply because a religious organization would benefit from a larger or different structure.

## Conclusion

The court concluded that Ann Arbor’s historic-district denial of Canterbury House’s demolition permit did not substantially burden religious exercise under RLUIPA because worship and ministry could continue at the site and other workable options existed, so the city was entitled to summary judgment.


Episcopal Student Found. v. City of Ann Arbor, 341 F. Supp. 2d 691 (E.D. Mich. 2004)