In Thai Meditation Association of Alabama, Inc. v. City of Mobile, Alabama, an Alabama federal district court dismissed a RLUIPA and 1st Amendment challenge to the city's denial of permission to build a meditation center and related structures in an area zoned residential. Plaintiff is a Buddhist religious organization. The court said in part:
The Court finds Plaintiffs have shown, for the purposes of summary judgment, the City’s decision effectively deprives them of any viable means by which to engage in protected religious exercise, but the application of the City’s Zoning Ordinance generally does not since the meditation center could be located at a commercially zoned property as of right....
... Plaintiffs have not demonstrated the City’s zoning decisions substantially burdened their religious exercise, and even if Plaintiffs’ religious exercise was substantially burdened by the denial of their Applications, the Court finds the decision was the least restrictive means to further the City’s compelling interest in its Zoning Ordinance...
