In Sandstrom v. Wendell, (WD NY, March 22, 2024), a New York federal district court rejected RLUIPA challenges to local tax officials' denial of a tax exemptions for two properties owned and converted to religious use by the Church of the Holy Redemption. Plaintiff, pastor of the church, argued that his religious exercise was substantially burdened by the denial. Tax officials contended that the Church did not qualify for a tax exemption. The court held in part:
[D]espite Plaintiff’s attempts to recharacterize his claims as amounting to a zoning challenge, ... Plaintiff has not plausibly alleged any burden on his religious beliefs apart from having to apply for tax-exempt status or being required to pay taxes. At its core, Plaintiff is seeking a federal court ruling on a local tax matter, which is specifically circumscribed by the Tax Injunction Act and principles of comity....
Here, Plaintiff has not alleged that he submitted a meaningful application to challenge the controversy or gave Defendants an opportunity to commit to a position intended to be “final.” Plaintiff does not allege that he completed the necessary requirements to challenge the properties’ status, commenced any appeal of the determination, or that such efforts would be futile, weighing against a finding that the claims are ripe....
