Background
Holy Trinity Ukrainian Catholic Church owns a 41-acre property in Collier Township, Pennsylvania, containing a cemetery and mausoleum. The parish proposed developing a religious shrine with a chapel, museum, gift shop, retreat center, and other features honoring Mary and the sanctity of life. Because the property spans two zoning districts and neither expressly permits the proposed shrine, Holy Trinity sought a zoning-code amendment and partial rezoning.
The Township’s Board of Commissioners denied the application after a public hearing, citing traffic and fundraising concerns. The record also included objections to the shrine’s pro-life message, including a commissioner’s statement that the Township may have “dodged a bullet” by rejecting it. Holy Trinity later obtained conditional approval for a smaller chapel but sued in federal court over the original proposal, alleging violations of the First Amendment and the Religious Land Use and Institutionalized Persons Act. The District Court denied a preliminary injunction, and Holy Trinity appealed.
The Court’s Holding
The Third Circuit affirmed, holding that the District Court did not abuse its discretion in denying preliminary relief. The majority concluded that Holy Trinity was very likely to prevail on its RLUIPA substantial-burden claim because the evidence suggested that another application would be futile and that opposition to the shrine’s religious message influenced the Township’s decision. The Township also had not shown that effectively barring the project was the least restrictive means of advancing a compelling interest.
Even so, the court held that likely success on the merits did not entitle Holy Trinity to a preliminary injunction. The existing zoning regime was the status quo, the parish waited approximately a year and a half to sue, and its requested relief was insufficiently specific. The court also found no irreparable injury requiring immediate intervention: fundraising delays could be compensated monetarily, the requested rezoning approval would not authorize construction, and the shrine was not expected to be completed for years. Judge Matey dissented, arguing that continued interference with religious land use caused irreparable harm and that the majority gave undue weight to preserving an allegedly discriminatory status quo.
Key Takeaways
- A strong likelihood of success on a RLUIPA claim does not by itself require a preliminary injunction.
- Evidence of religious hostility and the likely futility of reapplying can establish a substantial burden on religious land use.
- Delay in suing, vague requested relief, and the absence of time-sensitive religious harm may justify preserving the status quo until final judgment.
Why It Matters
The decision emphasizes that preliminary injunctions preserve a court’s ability to grant meaningful final relief rather than provide an early merits judgment. Religious institutions challenging zoning decisions must therefore identify specific interim relief and show that waiting for final judgment would cause harm that later remedies cannot repair.
At the same time, the court’s merits analysis signals serious concern about zoning decisions influenced by hostility to a religious project’s message. Although Holy Trinity did not obtain immediate relief, the majority stated that it had a solid RLUIPA case and could ultimately receive a final injunction permitting the shrine project to proceed.