## Facts

- A religious, educational, and charitable organization owned two adjoining buildings on Central Park West in Manhattan: a 1910 “Meeting House” used for services and administration, and a separate school building.
- The New York City Landmarks Preservation Commission designated the Meeting House a landmark under the city’s Landmarks Law.
- Landmark status restricted demolition and significant exterior alteration absent Commission approval and imposed exterior-maintenance obligations.
- The organization had explored redevelopment to capture increased property value (including potential high-rise development) to fund its charitable and educational work.
- The organization challenged the designation, arguing it was arbitrary, confiscatory, and an unconstitutional burden on religious and charitable activity.
- The trial court annulled the designation; the Appellate Division reversed; the state’s highest court reviewed and sustained the designation.

## Issues

1. Whether the landmark designation effected an unconstitutional taking or confiscatory land-use restriction without just compensation.
2. Whether applying a neutral landmark-preservation scheme to a religious organization’s house of worship violated free exercise of religion.
3. Whether the Commission’s designation was arbitrary and capricious or supported by substantial evidence and a rational basis.

## Decision

- The court affirmed the Appellate Division and upheld the landmark designation.
- The designation was sustained as a valid exercise of municipal police power through land-use regulation.
- No taking was found because the organization retained reasonable, beneficial use of the Meeting House for its ongoing religious and charitable functions.
- No free-exercise violation was found because the designation did not prevent or materially interfere with worship or current religious activities and was not targeted at religious institutions.
- The court relied in part on the availability of administrative hardship relief and the absence of a concrete, denied application demonstrating actual financial hardship.

## Legal Principles

- Landmark preservation laws may be applied to religious and charitable property as neutral, generally applicable land-use regulations.
- A restriction does not become a taking merely because it prevents the owner from pursuing the most profitable use; the question is whether reasonable beneficial use remains.
- A free-exercise claim is weakened where regulation imposes only incidental economic effects and does not substantially interfere with worship or religious practice.
- As-applied hardship claims are generally premature where the owner has not pursued available administrative relief mechanisms designed to address undue hardship.

## Conclusion

The court sustained the landmark designation of the Meeting House, holding that a neutral preservation law may limit redevelopment plans of a religious organization without compensation or a religious-liberty exemption when the property remains usable for religious purposes and no concrete, denied hardship relief shows confiscation.


Soc’y for Ethical Culture in the City of N.Y. v. Spatt, 51 N.Y.2d 449, 415 N.E.2d 922 (N.Y. 1980)