Thai Meditation Association of Alabama, Inc. v. City of Mobile, Alabama, 83 F.4th 922

Background

TMAA (a Dhammakaya Buddhist organization) purchased a house on Eloong Drive in Mobile zoned R-1 (residential), which requires Planning Commission approval for religious uses; TMAA previously operated in a residential house (denied) and a commercial space (unsatisfactory for worship).
TMAA applied for planning approval to convert the Eloong Drive property into a meditation center; public opposition—including comments focused on the Buddhist character of the group—followed and the Planning Commission denied the application; the City Council denied TMAA’s appeal.
TMAA sued the City raising RLUIPA (substantial burden), First Amendment Free Exercise, and Alabama Religious Freedom Amendment (ARFA) claims; after a bench trial this Court vacated/ remanded those three claims in Thai Meditation Ass’n of Ala. v. City of Mobile, 980 F.3d 821 (11th Cir. 2020) (TMAA I).
On remand the district court granted summary judgment to the City on all three claims; this appeal followed.
The Eleventh Circuit holds: summary judgment was improper for either party on the RLUIPA count (material factual disputes remain); summary judgment for the City on the Free Exercise claim is AFFIRMED (ordinance is neutral and generally applicable, so rational-basis review applies); summary judgment for the City on the ARFA claim is REVERSED and the court directs entry of judgment for TMAA (ARFA applies and City failed strict scrutiny).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
RLUIPA substantial-burden: did denial impose a "substantial burden" triggering strict scrutiny under 42 U.S.C. § 2000cc(a)(1)?	Denial coerces or significantly pressures TMAA to modify/abandon religious exercise; Planning Commission process was arbitrary and deprived TMAA of viable sites.	Denial was lawful zoning discretion; alternative sites (including a 100‑acre parcel owned by TMAA) exist; no substantial burden.	VACATED: summary judgment improper for either party—genuine, material factual disputes remain (e.g., alternative-site suitability; alleged procedural irregularities).
Free Exercise Clause: is Mobile’s R‑1 planning-approval process nonneutral or not generally applicable so as to trigger heightened scrutiny?	R‑1 process was applied in a way that targeted religious exercise or allowed individualized, secular exemptions.	The planning-approval criteria are neutral and apply uniformly to secular and religious uses; no impermissible individualized-exemption scheme.	AFFIRMED: process is neutral and generally applicable; rational-basis review applies and City’s interests in traffic/zoning are rationally related to legitimate interests.
ARFA (Alabama Religious Freedom Amendment): does ARFA apply and, if so, can City satisfy strict scrutiny (compelling interest/least restrictive means)?	ARFA applies to zoning; any burden (even incidental) triggers strict scrutiny; City cannot show a compelling interest or least-restrictive means.	ARFA should not reach zoning decisions or is narrower than federal protections; City contends neighborhood character and traffic are compelling interests.	REVERSED: ARFA applies to the zoning decision; City failed to show a compelling, specifically supported interest or least‑restrictive means (neighborhood character insufficient; traffic concerns unsupported), so judgment for TMAA is directed.

Key Cases Cited

Thai Meditation Ass’n of Ala. v. City of Mobile, 980 F.3d 821 (11th Cir. 2020) (prior panel decision remanding RLUIPA, Free Exercise, and ARFA issues)
Midrash Sephardi, Inc. v. Town of Surfside, 366 F.3d 1214 (11th Cir. 2004) (definition and standard for a RLUIPA "substantial burden")
Employment Div., Dep’t of Hum. Res. of Or. v. Smith, 494 U.S. 872 (1990) (neutrality and general applicability govern Free Exercise analysis)
Kennedy v. Bremerton Sch. Dist., 142 S. Ct. 2407 (2022) (clarifies neutrality and general-applicability principles under Free Exercise Clause)
Church of Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520 (1993) (strict scrutiny applies when government actions target religious practice)
Fulton v. City of Philadelphia, 141 S. Ct. 1868 (2021) (discusses individualized exemption mechanisms relevant to general applicability)
Solantic, LLC v. City of Neptune Beach, 410 F.3d 1250 (11th Cir. 2005) (aesthetics and traffic safety are not per se compelling interests)
Grosz v. City of Miami Beach, 721 F.2d 729 (11th Cir. 1983) (zoning objectives are significant in other balancing contexts, but not controlling under strict scrutiny)
Davila v. Gladden, 777 F.3d 1198 (11th Cir. 2015) (government must support compelling interests with specific, reliable evidence)