River of Life Kingdom Ministries v. Village of Hazel Crest, Illinois

Dist. Ct. did not err in denying plaintiff-church's motion for preliminary injunction in action under Religious Land Use and Institutionalized Persons Act to preclude defendant-Village from enforcing zoning ordinance that prevented plaintiff from locating church in commercial district of Village. Ct., in adopting test that focuses on accepted zoning criteria such as maintenance of separate commercial districts, found that instant ordinance did not violate RLUIPA where said ordinance also excluded other secular uses that were non-commercial in nature. (Dissent filed.)