## Facts

- The Roman Catholic Bishop of Springfield owned Our Lady of Hope Church in Springfield, Massachusetts.
- Amid diocesan reorganization and declining attendance, the Diocese considered closing the church and sought flexibility to sell or demolish the building.
- The City created a local historic district consisting of a single parcel: the church property alone.
- The ordinance subjected exterior alterations, including demolition, to review and approval by the local historical commission pursuant to Massachusetts historic-district authority.
- The Bishop alleged the designation impaired its ability to close, sell, or demolish the property and imposed financial and administrative burdens associated with maintaining and disposing of the building.
- The Bishop sued for declaratory and injunctive relief, asserting claims under RLUIPA and the Free Exercise Clause, as well as Equal Protection and substantive due process.
- The district court granted summary judgment to the City, and the Bishop appealed.

## Issues

1. Whether the single-parcel historic-district designation imposed a “substantial burden” on religious exercise under RLUIPA (and, relatedly, violated the Free Exercise Clause).
2. Whether the ordinance was a neutral, generally applicable land-use regulation, or instead targeted religious property in violation of the Free Exercise Clause.
3. Whether the designation unlawfully singled out the church property in violation of Equal Protection.
4. Whether creating a one-parcel historic district was so arbitrary or irrational as to violate substantive due process.

## Decision

- The First Circuit affirmed summary judgment for the City.
- The court held the designation did not impose a substantial burden on religious exercise under RLUIPA.
- The ordinance was facially neutral and generally applicable and therefore subject to rational-basis review under the Free Exercise Clause, which it satisfied.
- The Bishop failed to show discriminatory treatment or intent sufficient to support an Equal Protection claim.
- The ordinance was not “truly irrational” and did not violate substantive due process.

## Legal Principles

- A RLUIPA “substantial burden” requires more than indirect financial or administrative burdens; the plaintiff must show substantial pressure to modify religious behavior or exercise.
- When no substantial burden is shown under RLUIPA, a court need not apply RLUIPA’s strict-scrutiny test (compelling interest and least restrictive means).
- Under the Free Exercise Clause, a neutral and generally applicable law that incidentally affects religious exercise is reviewed for a rational basis.
- A regulation may be “generally applicable” even if it affects only one property, if it operates within a broader neutral regulatory scheme and is not motivated by hostility to religion.
- Under Equal Protection and substantive due process challenges to land-use decisions, rational-basis review is highly deferential; historic preservation is a legitimate governmental interest, and incremental or parcel-specific regulation is not unconstitutional without proof of discrimination or irrationality.

## Conclusion

The First Circuit upheld Springfield’s single-parcel historic district for Our Lady of Hope Church, concluding the designation regulated exterior features without substantially burdening religious exercise and was a neutral, rational historic-preservation measure that did not violate Free Exercise, Equal Protection, or substantive due process.


Roman Cath. Bishop of Springfield v. City of Springfield, 724 F.3d 78 (1st Cir. 2013)