Northridge Church v. Charter Township of Plymouth
647 F.3d 606
6th Cir.2011Background
- Northridge Church sought a special land-use permit in Plymouth Township in 1994 for a 55.8 acre site to build a church and related facilities.
- Plymouth Township Planning Board denied the initial application, initiating litigation.
- The parties entered a consent judgment in 1995 allowing Northridge to build and operate with numerous restrictions (auditorium seating capped at 3,500; parking capped at 1,167; parking restrictions; limited annual musical events; prohibited on-site soup kitchen/homeless shelter; traffic and outdoor-use limits).
- The district court retained jurisdiction to monitor and enforce the consent judgment.
- By the renewed litigation (2008), Northridge’s attendance grew dramatically (from about 1,100 to ~14,000), creating space and operational pressures and significant shuttle costs; Northridge moved to modify or set aside the judgment under Rule 60(b).
- The district court denied Northridge’s motion, and Northridge appealed leading to this Sixth Circuit decision affirming denial of modification.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the consent judgment is void under Rule 60(b)(4). | Northridge argues the judgment violated RFRA/RLUIPA and is void. | Plymouth contends the judgment was not void as to jurisdiction or due process. | Not void; no voidness under Rule 60(b)(4) for federal-law violation. |
| Whether Rule 60(b)(5) modification is warranted due to changed law. | RLUIPA changed the legal landscape, warranting modification. | RLUIPA’s enactment did not change the controlling legal standard from RFRA or law at the time of the decree. | No significant change in law; modification denied. |
| Whether changed factual circumstances justify modification under Rule 60(b)(5). | Significant growth and surrounding development render the decree unduly onerous. | Growth was largely anticipated; burden not sufficiently onerous or unforeseeable. | Changed factual circumstances did not warrant modification. |
Key Cases Cited
- Rufo v. Inmates of Suffolk Cnty. Jail, 502 U.S. 367 (U.S. 1992) (consent decree modification when obligations become impermissible or law changes; held as standard for continuing decrees)
- Kalamazoo River Study Group v. Rockwell Intl. Corp., 355 F.3d 574 (6th Cir. 2004) (consent decrees are often subject to Rule 60(b)(5); prospective nature discussed)
- United Student Aid Funds, Inc. v. Espinosa, 130 S. Ct. 1367 (U.S. 2010) (void judgment is a legal nullity; Rule 60(b)(4) limited to jurisdiction/due-process issues)
- East Brooks Books, Inc. v. City of Memphis, 633 F.3d 459 (6th Cir. 2011) (Rule 60(b) analysis; continuation of original proceedings; jurisdictional considerations)
- Antoine v. Atlas Turner, Inc., 66 F.3d 105 (6th Cir. 1995) (Rule 60(b)(4) standard; voidness if lack of jurisdiction or due process)