Problem Meeting Parking Requirements Can Be RLUIPA "Substantial Burden"

In Immanuel Baptist Church v. City of Chicago, (ED IL, July 20, 2020), an Illinois federal district court held that plaintiff Church adequately pleaded that the city's parking regulations imposed a "substantial burden" under RLUIPA on its religious exercise. The court said in part:

Church was burdened by substantial expense, time and resources trying to comply with the City’s parking requirements. Under the original deal it had with the owner of the Property, the Church intended to purchase two buildings. Because of the City’s determination that the Church did not comply with its parking requirements, the Church was not able to close on the deal in 2016. Then when it was able to close on the deal two years later, the Church was only able to purchase one building. And during that delay, the Church spent money paying rent and used significant resources trying to negotiate with the City and identify potential parking solutions. Although the City finally exempted the Church from the parking requirement in 2019, that did not change the fact that the Church had spent significant time, money, and resources over those years, and lost the opportunity for ownership of one of the buildings. All of this was particularly difficult for the Church which has great needs and very limited resources....