Thai Meditation Association v. City of Mobile

The Thai Meditation Association of Alabama bought a large wooded lot in a residential section of Mobile, Alabama, on which it wished to build a small Buddhist meditation center. The meditation association applied for planning approval, but the City of Mobile completely denied the application to build the meditation center and said nothing to suggest that a modified application would be approved. The meditation association then sued the City of Mobile.

After the district court ruled in favor of the city, the meditation association appealed to the Eleventh Circuit, arguing that the district court applied the wrong standard and recommending that the Eleventh Circuit adopt a multi-factor approach for evaluating substantial burden claims, an approach similar to that used in most other circuits. On November 16, 2020, the Eleventh Circuit agreed and reversed the district court’s decision, laying out a multi-part test to be applied on remand.

On remand, the district court again entered summary judgment for the city. While the district court correctly ruled that “the City’s decision effectively deprives [Plaintiffs] of any viable means by which to engage in protected religious exercise,” the district court nonetheless granted summary judgment for the city on the meditation association’s claim under RLUIPA on the ground that the city’s decision did not “impose[] a substantial burden on the religious exercise of [plaintiffs].” The meditation center again appealed to the Eleventh Circuit.

On September 15, 2022, the Center, along with the American Hindu Foundation and the Coalition for Jewish Values, filed an amicus brief in support of the meditation center and its efforts to seek a reversal of the district court’s latest decision. The Center’s brief argued that the district court’s ruling violates three critical principles underlying RLUIPA. The Center also argued that the district court essentially adopted a standard that could rarely, if ever, be met and that the district court’s decision jeopardizes the integrity of the substantial burden inquiry, both in the Eleventh Circuit and elsewhere, and should be overturned.