Bethel World Outreach Ministries v. Montgomery County Council, No. 11-2176 (4th Cir. 2013)
Annotate this CaseBethel brought this action asserting that the County's zoning regulations, which prevented Bethel from constructing a church, violated the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq., the United States Constitution, and the Maryland Declaration of Rights. The district court granted summary judgment to the County on all claims. The court concluded that the County had presented no evidence that its interest in preserving the integrity of the rural density transfer zone could not be served by less restrictive means, like a minimum lot-size requirement or an individualized review process. Therefore, the court reversed the district court's grant of summary judgment to the County on Bethel's substantial burden claim. The court affirmed in all other respects and remanded for further proceedings.
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