111 F.4th 814
7th Cir.2024Background
- Word Seed Church (now Grace Fellowship Covenant Church) sought to establish a permanent location within the Village of Hazel Crest, Illinois but faced difficulties allegedly due to the village's zoning ordinance.
- The zoning ordinance did not list churches as a permitted use in any of its nine districts and allowed them only as a special use in three residential zones, requiring a multi-step permitting process.
- The Church sued, arguing the ordinance discriminated against religious assemblies in violation of the Equal Protection Clause and RLUIPA, and was unconstitutionally vague.
- The district court denied the church's motion for a preliminary injunction, found standing, but ultimately granted summary judgment for the village and rejected all claims on the merits.
- The church did not appeal the summary judgment but instead filed a Rule 60(b) motion for relief, arguing the district court applied the wrong version of the ordinance; the court denied that motion, and the church appealed only that denial.
- During the appeal, the church had purchased property outside Hazel Crest, mooting injunctive relief, but continued seeking nominal damages on the Equal Protection claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing and Mootness | Church was injured by ordinance; nominal damages claim remains live | Case is moot due to new property and no actual injury | Claim for nominal damages prevents mootness; standing adequate at summary judgment stage |
| Jurisdiction on Appeal of Rule 60(b) Motion | District court applied wrong zoning version, harming church's rights | No egregious jurisdictional error; Rule 60(b) not for ordinary errors | No egregious error; district court's jurisdiction stands |
| Application of Correct Zoning Ordinance | District court should’ve applied pre-2008 code, affecting comparators | Church waived argument, and outcome unchanged regardless | District court did not abuse discretion in denying relief |
| Equal Protection on Zoning Process | Ordinance imposed greater burdens on religious groups | Ordinance treated all comparably; no discrimination | No error in judgment; church's difficulty was property size, not discrimination |
Key Cases Cited
- Arbaugh v. Y & H Corp., 546 U.S. 500 (federal courts must independently verify subject-matter jurisdiction)
- Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (must determine subject-matter jurisdiction before merits)
- Carey v. Piphus, 435 U.S. 247 (nominal damages recognized for constitutional rights violations)
- Insurance Corp. of Ireland v. Compagnie des Bauxites de Guinee, 456 U.S. 694 (jurisdictional determinations may have preclusive effect)
- Stoll v. Gottlieb, 305 U.S. 165 (courts have authority to determine their own jurisdiction)