Spirit of Aloha Temple v. County of Maui (9th Cir.)
The Notre Dame Law School Religious Liberty Clinic filed an amicus brief in support of Spirit of Aloha Temple and its founder, a Hindu monk, urging the court to protect their right to use their property for religious practice. The Clinic’s brief details the legal protections offered by the Religious Land Use and Institutionalized Persons Act (RLUIPA), which tightly circumscribes the government’s authority to substantially burden a person’s religious exercise through its land-use decisions.
Spirit of Aloha Temple is a religious organization that adheres to the Integral Yoga movement, a modern branch of the ancient Hindu yogic tradition. Its founder, Fredrick Honig, is a Hindu monk who cares for the Temple’s property. For many years, the property hosted religious services and sacred events including baptisms and weddings, and offered classes on spiritual beliefs. After County officials notified the Temple that it was not permitted to engage in religious services, ceremonies, yoga, and other religious and educational events on its property, the Temple applied for a special use permit to continue its religious exercise. The County officials denied its request. The Temple and Mr. Honig filed suit in federal court, seeking relief under RLUIPA.
Our brief explains that, to determine whether a land-use regulation unlawfully imposes a substantial burden on a plaintiff’s religious exercise, courts conduct a holistic and nuanced inquiry. At bottom, that analysis asks whether and to what extent the government has impaired the plaintiff’s ability to fulfill a religious need. The lower court here badly misconstrued that inquiry by imposing a requirement that RLUIPA does not create, and by sending the legal determination of substantial burden to a jury.
Our brief urges the Ninth Circuit to correct the district court’s fundamental misunderstanding of RLUIPA’s religious protections, both to fix the erroneous decision and to ensure that other courts will not repeat the same mistake.
Case Documents
Press Releases
- "Notre Dame Religious Liberty Clinic supports Hindu organization’s freedom to use its property for religious practice" by Arienne Calingo, published by Notre Dame Law School (March 13, 2024)
Meet the Team
-
Director, Religious Liberty Clinic
Term Teaching Professor -
Staff Attorney, Religious Liberty Clinic
-
Student Fellow
-
Student Fellow
-
Student Fellow
-
Student Fellow