Miles Christi Religious Order v. Township of Northville
629 F.3d 533
6th Cir.2010Background
- Miles Christi, a religious order, owns a five-bedroom house in Northville, used for private Masses and Bible studies, in a residential zone with no obvious church-like exterior.
- Township officials determined in 2007 that Miles Christi's use had intensified beyond residential use, triggering site-plan and parking requirements for churches under Northville ordinances.
- Bauer, the Ordinance Enforcement Officer, and Frey, Director of Community Development, sought a site plan and parking improvements, including rear-yard parking, and warned of a variance or site-plan requirements.
- Miles Christi faced state-court enforcement after a ticket for violating site-plan review procedures; ongoing state proceedings paralleled the federal suit.
- Miles Christi filed a federal suit on September 21, 2007, asserting violations of RLUPIA, First and Fourteenth Amendments, and Michigan Constitution; district court dismissed as unripe.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are Miles Christi's claims ripe despite no final zoning decision? | Miles Christi: no final decision; zoning board input needed. | Northville: final decision required before review; should exhaust administrative remedies. | No final decision; claims unripe. |
Key Cases Cited
- Williamson Cnty. Reg'l Planning Comm'n v. Hamilton Bank of Johnson City, 473 U.S. 172 (1985) (finality requirement for regulatory takings)
- Grace Cmty. Church v. Lenox Twp., 544 F.3d 609 (6th Cir. 2008) (ripeness where local process not utilized)
- Warshak v. United States, 532 F.3d 521 (6th Cir. 2008) (ripeness factors; concrete context and hardship)
- Lucas v. S. Coastal Council, 505 U.S. 1003 (1992) (finality and administrative remedies in takings context)
- MacDonald, Sommer & Frates v. Cnty. of Yolo, 477 U.S. 340 (1986) (finality depends on how far regulation goes)
- Suitum v. Tahoe Reg'l Planning Agency, 520 U.S. 725 (1997) (variance and final determinations in land-use)
- Insomnia Inc. v. City of Memphis, 278 F. App'x 609 (6th Cir. 2008) (threshold analysis for First Amendment land-use claims)
- Murphy v. New Milford Zoning Comm'n, 402 F.3d 342 (2d Cir. 2005) (First Amendment ripeness with local review options)