In
Wesleyan Methodist Church of Canisteo v. Village of Canisteo,
2011 U.S. Dist. LEXIS 58586 (WD NY, June 1, 2011), a New York federal district court held that a church had failed to plausibly plead that denial of its zoning request by the Village of Canisteo, NY imposed a substantial burden on the church's free exercise rights under
RLUIPA. The city refused to permit building of a church in a light industrial zone. However, several other alternatives were available to the church, including building new structures on its existing property.