Jesus Christ is the Answer Ministries, Inc. v. Baltimore County, No. 18-1450 (4th Cir. 2019)Annotate this Case
The Church and Reverend appealed the district court's dismissal of their claims against the county and board under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the Free Exercise Clause, the Equal Protection Clause, and Article 36 of the Maryland Declaration of Rights. This action stemmed from the board's dismissal of a second petition to approve the use of plaintiff's property as a church.
The Fourth Circuit held that the district court erred by dismissing plaintiffs' RLUIPA claim because plaintiffs have sufficiently alleged that the dismissal of the second petition imposed a substantial burden on their religious practice; the complaint plausibly alleged a prima facie claim of religious discrimination; and, while the county may have a significant interest in finality and economy that would ordinarily be served by the doctrines of res judicata and collateral estoppel, the dismissal of the second petition was not narrowly tailored to serve that interest because the second petition did not seek to revisit the board's decision about the first petition. Accordingly, the court vacated these claims and remanded for further proceedings. The court also vacated the state constitutional claim.
The court issued a subsequent related opinion or order on February 25, 2019.