Affordable Recovery Housing v. City of Blue Island

Federal 7th Circuit Court
Civil Court
Illinois Religious Freedom Restoration Act
Citation
Case Number: 
No. 16-3677
Decision Date: 
June 21, 2017
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in granting plaintiff’s motion for partial summary judgment in action seeking to enjoin order obtained by defendant to evict residents of plaintiff’s drug rehabilitation facilities, where said facilities lacked sprinkler system, since said residents were subsequently allowed to return to plaintiff’s facilities pursuant to issuance of license by Ill. Dept. of Human Services that designated plaintiff’s buildings as recovery houses that did not require installation of sprinkler system. Moreover, Dist. Ct. did not err in denying plaintiff’s claim that it was entitled to similar relief under Ill. Religious Freedom Restoration Act, since, although plaintiff argued that providing recovery services for drug-addicted men typified Christian charity, plaintiff failed to assert that sprinkler system requirement would have substantially burdened plaintiff’s religious exercise, even if it had complied with requirement for sprinkler installation.