Pittsfield Charter Township, through its Planning Commission and Board of Trustees, denied a rezoning application submitted by the Muslim Community Association of Ann Arbor, doing business as Michigan Islamic Academy (“MIA”). According to MIA, the denial of the rezoning application meant that it could not build a new Islamic school on property within Pittsfield Township that it wished to utilize for that purpose. MIA claimed that the Township’s decision to deny the rezoning application was based on hostility toward Islam, and asserted claims under the Religious Land Use and Institutionalized Persons Act (“RLUIPA”), the United States Constitution, and the Michigan Constitution.
The District Court granted the Township’s motion for Summary Judgment (with leave to amend) on the grounds that MIA had not offered any evidence showing that it had, or had ever had, a legally cognizable interest in the property.