In Caractor v. City of New York Department of Homeless Services, (SD NY, June 14, 2013), a New York federal district court rejected free speech, free exercise and equal protection challenges by the head of the Discovered Being Ministry to New York's refusal to permit him to conduct Christian religious services inside city homeless shelters. The court concluded that homeless shelters are non-public forums and that "DHS’s decision to limit access to external organizations that either assist in providing shelter, aid shelter residents to find permanent housing, or provide services mandated or authorized by law -- a restriction which consequently excludes religious organizations -- is both reasonable and viewpoint
neutral."
