Roman Catholic Bishop v. City of Springfield, 2013 U.S. App. LEXIS 14781

The Roman Catholic Bishop of Springfield (RCB) owns Our Lady of Hope Church, closed for worship Jan. 1, 2010 after diocesan pastoral planning; RCB follows canon-law deconsecration procedures before sale/alteration of closed churches.
Springfield enacted a single-parcel historic-district ordinance covering only the Church shortly after news of the closure; designation requires SHC approval for any exterior alteration and can bar demolition without a certificate.
RCB sued the City the day after the ordinance took effect, asserting federal constitutional claims, RLUIPA claims, and Massachusetts constitutional claims; district court granted summary judgment to the City and held some claims unripe.
On appeal, the First Circuit treated as ripe only RCB’s challenge to the mere enactment of the ordinance; claims contingent on future SHC decisions (e.g., denial of deconsecration or demolition) were held unripe and dismissed without prejudice.
On the ripe claim, the court concluded the ordinance did not impose a "substantial burden" under RLUIPA, did not violate RLUIPA’s equal-terms provision (no adequate comparator shown), and did not violate the First Amendment free-exercise clause or the analogous Massachusetts provision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ripeness: challenge to future SHC actions	Ordinance itself (and the need to apply to SHC) creates immediate injury and futility of applying	Claims dependent on hypothetical future SHC action are premature absent an application/final decision	Only challenge to mere enactment is ripe; claims about future SHC outcomes are unripe and dismissed without prejudice
RLUIPA substantial-burden	Ordinance forces RCB to submit religious deconsecration decisions to secular review, imposing delay, expense, and potentially preventing deconsecration/demolition	Ordinance is a land-use regulation; any burdens are not "substantial" and are speculative absent concrete SHC action	No substantial burden shown from mere enactment; RCB failed to prove present, significant pressure to modify religious practice
RLUIPA equal-terms	Single-parcel designation of a church treats RCB worse than secular entities	City can designate any parcel as historic; RCB offered no similarly situated secular comparator	Failed: RCB did not identify a relevant secular comparator; claim rejected
Free exercise / Massachusetts Constitution	Ordinance subordinates religious decisions to secular veto, warranting strict scrutiny and invalidation	Ordinance is neutral in operation and does not target religion; any claim is speculative until SHC acts	Mere enactment did not impose a constitutional substantial burden; federal and state free-exercise claims fail as to ripe challenge

Employment Div. v. Smith, 494 U.S. 872 (Sup. Ct.) (neutral, generally applicable laws and Free Exercise).
City of Boerne v. Flores, 521 U.S. 507 (Sup. Ct.) (limits on Congress's enforcement power over states re RFRA).
Cutter v. Wilkinson, 544 U.S. 709 (Sup. Ct.) (constitutionality of RLUIPA).
Church of Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (Sup. Ct.) (government action targeting religion triggers strict scrutiny).
Williamson County Reg'l Planning Comm'n v. Hamilton Bank, 473 U.S. 172 (Sup. Ct.) (ripeness/administrative exhaustion in regulatory takings context).
Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418 (Sup. Ct.) (context-sensitive Free Exercise analysis).
Penn Cent. Transp. Co. v. City of New York, 438 U.S. 104 (Sup. Ct.) (landmark/land-use regulation principles).