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ZN 93-02 � ` i r � \ T Y O G .c� <� ti 5 ^tgust 24, 1993 ° P K , � Planning Report ZN93-2 ORDINANCE AMENDMENT- RELIGIOUS INSTITUTIONS Proaosed Action. • Staff recommends the following motion: Move to annrove Resolution RZ 93-10 recommending a�proval of Ordinance 93-725 amendine the Zoning, Ordinance to�ermit reli�ious institutions as a conditional use permit within the B-2 and B-3 zoning districts Overview. In 1991 a moratorium was placed on permitting churches in the B-2 and B-3 zoning district in order to give the Commission time to review a possible ordinance change. Last October the City Council e}ctended the moratorium until October 1993. The moratorium can be e�ctended for an additional six months At the March Zoning and Planning meeting the Planning Commission reviewed the information provided by the staff and asked the staff to draft an ordinance prohibiting churches in the B-2 and B-3 zoning districts. The staff had recommended that religious institutions be regulated by a conditional use permit. After reviewing additional information of prohibiting religious institutions in the business district, it was determined that the elimination of ^ ;ious institutions in the business district raised some constitutional issues. As a result of reviewing further �rmation, the Commission directed staff to draft an ordinance that would permit religious institutions in the B-2 and B-3 zoning districts with a conditional use permit. With this action a church would need to meet the conditions outlined in the ordinance prior to receiving a permit to locate in the B-2 and B-3 districts. The City Attorney has recommended that if the City desires to eliminate religious institutions from the business districts, a study should be completed to support this decision. Primarv Issues to Consider. o Why was the moratorium proposed? o What are the legal issues regarding prohibiting churches in business districts? o Where will religious institutions be allowed if the attached ordinance is adopted? o What is the basis of the staff recommendation? Sunnorting Documents. o Analysis of Issues o Resolution RZ93-10 o Ordinance 93-725 '�rn � �.�� Nancy . Anderson, AICP P�iner . - _, �._ - �-� - ; . - . , - - s . . . .. _ ._ .:. � ,. . . _ .,. :._ , _ .. .. ., . _ r- . .. � _ . � ZN93-2 Page 2 � Primary Issues to consider. o Why was the moratorium proposed? The moratorium was proposed by staff in order to give the Planning Commission time to review a possible ordinance change which would restrict the location of religious institutions in the B-2 and B-3 districts. These districts are more intense commerciaUretail in nature and there was a concern about the compatibility of religious institutions with the other commercial uses allowed in these districts. The Zoning Ordinance currently allows religious institutions as a permitted use in all the residential districts and the business districts. o What are the legal issues regarding prohibiting religious institutions in the business districts? The City Attorney has recommended that if religious institutions are prohibited in the B-2B-3 zoning districts a study should to be completed. The study would need to justify the reasons for eliminating religious institutions in commercial area by detailing the negative impacts they would have in such areas. If religious institutions are excluded from the business districts without any clearly defined reasons the City could be subject to future legal action and the subsequent legal costs from the group bringing the legal action if the City lost the case. There was a recent case in Hastings that is similar to the situation in Hopkins. The facts of the case are a.,� follows: o Cornerstone Bible Church located its church in a commercial zone (C-3) in downtown Hastings. o Churches are not allowed in the C-3 zoning district. o The church requested that the property be rezoned or the Zoning Ordinance amended to allow churches in commercial areas. This request was denied by the City. The Church challenged the City's ordinance of excluding churches from the central business district as a violation of its rights to free speech, freedom of association, free exercise of religion, equal protection and due process. The court decision was in favor of the church. There decision was based on the fact that: "The City has not provided factual support for the assumptions that underlies its exclusion of churches, and the alleged secondary effects of churches on commercial activity remain a disputed factual issue." The court also stated the following regarding the basis for the City denying the churches from the C-3 district. "The City presented affidavits from two city planners containing little more than conclusory statements that excluding churches from the C-3 zone is consistent with the City's planning process and historical land-use." o Where wiil churches be allowed if the attached ordinance is adopted? Religious institutions will still be allowed in the residential districts and the B-1 business district as a permittea�,,,, use. In the B-2 and B-3 district they will also still be allowed but will require approval of a conditional use permit. ZN93-2 Page 3 � What is the basis of the staff recommendation? The staff is recommending that religious institutions are allowed by conditional use permit in the B-2 and B-3 zoning districts. By undertaking this action it will not be necessary for the City to expend time and funds necessary to complete a study to justify this action. Religious uses would remain permitted in the B-2 and B-3 zoning districts with a conditional use permit and therefore there should be no basis for legal action against the City unless an applicant is denied a conditional use permit for reasons which they feel are arbitrary and capricious. Staff is recommending a variety of conditions that religious institutions would need to comply with for approval of a conditional use permit. The conditions are meant to reduce potential negative impacts and insure compatibly of religious institutions with more traditional retail uses being located side by side in these districts. Staff is recommending that churches are allowed in the B-1 district. The B-1 business district is a limited business area, which is not as retail oriented as the B-2 and B-3 districts. Alternatives 1. Recommend approval of Ordinance 93-725. By recommending approval of Ordinance 93-725 the City Council will consider a recommendation of permitting religious institutions in the B2B-3 zoning districts with a conditional use permit. 2. By recommending denial of the Ordinance 93-725, the City Council will consider a recommendation of denial for allowing religious institutions as a conditional use permit in the B-2 and B-3 zoning districts. The present ordinance would remain in force for religious institutions as a permitted use within all the business districts if the City Council considers this alternative. 3. Continue for further information. If the Commission indicates that further information is needed, the item should be continued. The moratorium will expire in October if the City Council does not extend the moratorium. 4. Recommend that a study is conducted to determine the positive and/or negative affects of religious institutions in commercial areas. If the Commission indicates that a study should be conducted, this item should be continued. �� CITY OF HOPKINS Hennepin County, Minnesota � ORDINANCE NO 93-725 BE IT ORDAINED by the City Council of the City of Hopkins as follows: That the Hopkins Zoning Ordinance No. 535 be and the same is hereby amended by amending the following sections: 535.01 subd. 3. B-1 B-2 B-3 109. Religious institutions, etc X (2)XDD (2) XDD 535.03 subd. 2 DD DD) Religious Institutions provided: 1. That there shall be no permanent or temporary living units on the property except for the parsonage. 2. That there is adequate screening or buffering provided from abutting residential districts. 3. That there is adequate off-street loading and service entrances as detailed in section 550.09. 4. That there shall be no religious institution within 350 feet of a off sale or on sale liquor establishment. 5. That there shall be no religious institution within 350 feet of an adult oriented business. �— 6. That the building occupying the religious institution shall meet the building occupancy codes. 7. That a religious institution located in the B-3 district shall comply with the parking requirements of section 550.05. First Reading: September 7, 1993 Second Reading: September 21, 1993 Date of Publication: September 29, 1993 Date Ordinance Takes Effect: October 19, 1993 Charles D. Redepenning, Mayor ATTEST: James A. Genellie, City Clerk �— CITY OF HOPKINS �, Hennepin County, Minnesota RESOLUTION NO: RZ93-10 RESOLUTION MAKING FINDINGS OF FACT AND RECOMMENDING APPROVAL OF AN APPLICATION FOR AN ORDINANCE AMENDMENT WHEREAS, an application for an Ordinance Amendment ZN 93-2 made by the City of Hopkins is recommended for approval. WHEREAS, the procedural history of the application is as follows: l. That an application for an ordinance amendment ZN 93-2 was filed with the City of Hopkins on April 23 , 1993 . 2 . That the Hopkins Planning Commission reviewed such application on June 29, 1993 , July 27, 1993 , and August 31, 1993 . 3 . That the Hopkins Planning Commission, pursuant to published notice, held a public hearing on the ^ application on June 29, 1993, July 27, 1993 , and August 31, 1993 : all persons present at the hearing were given an opportunity to be heard. 4. That the written comments and analysis of the City staff and the Planning Commission were considered. NOW THEREFORE, BE IT RESOLVED that the application for ZN 93-2 is hereby recommended for approval based on the following Findings of Fact: 1. That religious institutions will be permitted with a conditional use permit in the B-2 and B-3 zoning districts. Adopted this 31st day of August, 1993 . Patricia M. Reuter, Chairman � . � Minnesota Suburban Newspapers City of Hopkins (O(flcial P�bNtation) CITY OF HOPKINS . _ AFFIDAVIT OF PUBLICATION Hennepin County.,�„��aa ORDINANCE NO.91-693 �� AN ORDINANCE ESTABLISHING A MORATORIUM ON REIIGIOUS INSTITUTIONS IN 7HE b2 AND B-3 ZONING DIS7'AICI'S STATE OF MINNESOTA) prd�n e No sts s�o a��aaz�� SS. ��REAS,it has been determined that it is necassary f�the health.saf anl welfare� COUNTY OF HENNEPIN) t}�eres�dentsoftheG�tyofHo�toswdyand crosiaer an ame,rh�,ent to ttus o�dinance regar& ing reGgious institutiom in(�e&2 and B-3 zon- G r e�o r v P t a c i n , being duly sworn on an oath says that he/she �� h[;�,esora sta�e smcu�es aa.ass subd.4 allows a city to adopl an interim ac�nance when underfaking study to revise fhe zoninq a'- the publisher or authorized agent and employee of the publisher of the newspaper known �o���pg�gE 1T ORDAINED by the City of Hopkins.Minnesota, H o c k i n s S u n—S a 1 I o r m�wr;�,s�D1i���`'p�osea u�u�`a�i , and has full knowledge of the facts which � d all religious i,�stitutians in the a-z and -s z�- u�g districts. This moratorium ehall be ior the purpose ot stated below. au�ing rne crtr�r eo.p�c�eway�a�� an ameodmeot a tbe woiog ordlaoanoe reB�B re�gbus inatiWtimg in the&2 and g3 zoning � �A The news a er has com lied with all of the re uirements constitutin ualification as a ualified news 8 ���andshalle:pinOctober8.�9sza�n� P P P �l 9 q Q P P'�he enac►ment d a zoniog amendment cmcero- ing this matter,whkhevv comes Mt. Secocd Rea�du�B:. SeP�m�betr�,1991 as provided by Minnesota Statute 331A.02, 331A.07, and other applicable laws, as amended. Dece of r�,bu�a�«�: �m��,� Date Ord.is Effective: October 8,1991 (B)The printed a r d i n a n c e N o. 91-6 9 3 NEISON W.B`�ER�G ATCFST: JAhfFS A.GENELLIE �ty Clerk (Sept.ll,1991)-HOP which is attached was cut from the columns of said newspaper, and was printed and published once each week, for �n¢ successive weeks; it was first published on we dnQ a d a y , the 11 day '�_� of S e P t , 1g 91 , and was thereafter printed and published on every to and including , the day of , 19 ; and printed below is a copy of the lower case alphabet from A to Z, both inclusive, which is hereby acknowledged as being the size and kind of type used in the composition and publication of the notice: abcdefghi jklm nopqrs[uvw xyz BY: . TITLE: GQrle 1'�! I ManaEQr Acknowledged before me on this 11 dayof Sevtembar 1 91 . � �, , Not Public RATE INFORMATION .-• (1) Lowest classified rate paid by commercial users $ 1.10 per line for comparable space (Line, word, Or inch rate) (2)Maximum rate allowed by law for the above matter $ 74.9¢ per line (Line, word, or inch rate) (3)Rate actually charged for the above matter $ 62¢ per line (Line, word, or inch rate) . , \ j Y O G � ������� � ti 5 �ptember 1, 1993 ° P K � � Council Report 93-149 ORDINANCE AMENDMENT- RELIGIOUS INSTITUTIONS Proposed Action. Staff recommends the following motion: Move to annrove Resolution 93-93 a�provin� Ordinance 93-725 for first readin� which amends the Zoning Ordinance to�ermit reli�ious institutions as a conditional use permit wrtlun the B-2 and B-3 zoning districts for first readin� Mr. Hutchison moved and Mr. Johnson seconded a motion approving Resolution RZ93-10 recommending approval of Ordinance 93-725. The motion was approved unanimously. Overview. In 1991 a moratorium was placed on permitting churches in the B-2 and B-3 zoning district in order to give the Commission time to review a possible ordinance change. Last October the City Council extended the moratorium until October 1993. The moratorium can be extended for an additional six months At the March Zoning and Planning meeting the Planning Commission reviewed the information provided by the staff and asked the staff to draft an ordinance prohibiting churches in the B-2 and B-3 zoning districts. The staff had recommended that religious institutions be regulated by a conditional use permit. After reviewing additional "`�rmation of prohibiting religious institutions in the business district, it was deternuned that the elimination of �ious institutions in the business district raised some constitutional issues. As a result of reviewing further mformation, the Commission directed staff to draft an ordinance that would permit religious institutions in the B-2 and B-3 zoning districts with a conditional use permit. With this action a church would need to meet the conditions outlined in the ordinance prior to receiving a permit to locate in the B-2 and B-3 districts. The City Attorney has recommended that if the City desires to eliminate religious institutions from the business districts, a study should be completed to support this decision. The staff reviewed the proposed amendment with the Planning Commission on August 31. Staff noted that the proposed amendment had been reviewed by the Commission for the past several months. There was little discussion on this item. Primarv Issues to Consider. o Why was the moratorium proposed? o What are the legal issues regarding prohibiting churches in business districts? o Where will religious institutions be allowed if the attached ordinance is adopted? o What is the basis of the staff recommendation? Supportin� Documents. o Analysis of Issues �-- o Resolution 93-93 o Ordinance 93-725 ��� � � �� Nancy S derson, AICP Planner CR93-149 Page 2 ,� Primary Issues to consider. o Why was the moratorium proposed? � The moratorium was proposed by staff in order to give the Planning Commission time to review a possible ordinance change which would restrict the location of religious institutions in the B-2 and B-3 districts. The B-2 district encompasses the downtown area. The B-3 district encompasses other commercial areas in the City. These districts are more intense commerciaUretail in nature and there was a concern about the compatibility of religious institutions with the other commercial uses allowed in these districts. The Zoning Ordinance currently allows religious institutions as a permitted use in all the residential districts and the business districts. o What are the legal issues regarding prohibiting religious institutions in the business districts? The City Attorney has recommended that if religious institutions are prohibited in the B-2B-3 zoning districts a study should to be completed. The study would need to justify the reasons for eliminating religious institutions in commercial area by detailing the negative impacts they would have in such areas. If religious institutions are excluded from the business districts without any clearly defined reasons the City could be subject to future legal action and the subsequent legal costs from the group bringing the legal action if the City lost the case. There was a recent case in Hastings that is similar to the situation in Hopkins. The facts of the case are as follows: o Cornerstone Bible Church located its church in a commercial zone (C-3) in downtown Hastings. o Churches are not allowed in the C-3 zoning district. o The church requested that the property be rezoned or the Zoning Ordinance amended to allow churches in commercial areas. This request was denied by the City. The Church challenged the City's ordinance of excluding churches from the central business district as a violation of its rights to free speech, freedom of association, free exercise of religion, equal protection and due process. The court decision was in favor of the church. There decision was based on the fact that: "The City has not provided factual support for the assumptions that underlies its exclusion of churches, and the alleged secondary effects of churches on commercial activity remain a disputed factual issue." The court also stated the following regarding the basis for the City denying the churches from the C-3 district. "The City presented affidavits from two city planners containing little more than conclusory statements that excluding churches from the C-3 zone is consistent with the City's planning process and historical land-use." o Where will churches be allowed if the attached ordinance is adopted? Religious institutions will still be allowed in the residential districts and the B-1 business district as a permitted� use. In the B-2 and B-3 district they will also still be allowed but will require approval of a conditional use permit. CR93-149 Page 3 --� o What is the basis of the staff recommendation? The staff is recommending that religious institutions are allowed by conditional use permit in the B-2 and B-3 zoning districts. By undertaking this action it will not be necessary for the City to expend time and funds necessary to complete a study to justify this action. Religious uses would remain permitted in the B-2 and B-3 zoning districts with a conditional use permit and therefore there should be no basis for legal action against the City unless an applicant is denied a conditional use permit for reasons which they feel are arbitrary and capricious. Staff is recommending a variety of conditions that religious institutions would need to comply with for approval of a conditional use permit. The conditions are meant to reduce potential negative impacts and insure compatibly of religious institutions with more traditional retail uses being located side by side in these districts. Staff is recommending that churches are allowed in the B-1 district. The B-1 business district is a limited business area, which is not as retail oriented as the B-2 and B-3 districts. The B-2 district essentially encompasses the downtown area. The B-3 district encompasses other general retaiVcommercial areas in the City. Alternatives � Approve Ordinance 93-725. By approving Ordinance 93-725, religious institutions will be permitted by Conditional Use Permit in the B2B-3 zoning districts. 2. Deny Ordinance 93-725. By denying Ordinance 93-725, the present ordinance would remain in force for religious institutions as a permitted use within all the business districts. 3. Continue for further information. If the City Council indicates that further information is needed, the item should be continued. The moratorium will expire in October if the City Council does not extend the moratorium. 4. Recommend that a study is conducted to determine the positive and/or negative affects of religious institutions in commercial areas. If the City Council indicates that a study should be conducted, this item should be continued. � CITY OF HOPKINS � Hennepin County, Minnesota ORDINANCE NO 93-725 BE IT ORDAINED by the City Council of the City of Hopkins as follows: That the Hopkins Zoning Ordinance No. 535 be and the same is hereby amended by amending the following sections: 535.01 subd. 3. B-1 B-2 � B-3 109. Religious institutions, etc X (2)XDD (2) XDD 535.03 subd. 2 DD DD) Religious Institutions provided: 1. That there shall be no permanent or temporary living units on the property except for the parsonage. 2. That there is adequate screening or buffering provided from abutting residential districts. 3. That there is adequate off-street loading and service entrances as detailed in section 550.09. 4. That there shall be no religious institution within 350 feet of a off sale or on sale liquor establishment. � 5. That there shall be no religious institution within 350 feet of an adult oriented business. 6. That the building occupying the religious institution shall meet the building occupancy codes. 7. That a religious institution located in the B-3 district shall comply with the parking requirements of section 550.05. First Reading: September 7, 1993 Second Reading: September 21, 1993 Date of Publication: September 29, 1993 Date Ordinance Takes Effect: October 19, 1993 Charles D. Redepenning, Mayor � ATTEST: � James A. Genellie, City Clerk "`' CITY OF HOPKINS Hennepin County, Minnesota RESOLUTION NO: 93-93 RESOLUTION MAKING FINDINGS OF FACT AND APPROVING AN APPLICATION FOR AN ORDINANCE AMENDMENT WHEREAS, an application for an Ordinance Amendment ZN 93-2 made by the City of Hopkins is approved. WHEREAS, the procedural history of the application is as follows: 1. That an application for an ordinance amendment ZN 93-2 was filed with the City of Hopkins on April 23, 1993 . 2 . That the Hopkins Planning Commission reviewed such application on June 29, 1993 , July 27, 1993, and August 31, 1993 . 3. That the Hopkins Planning Commission, pursuant to published notice, held a public hearing on the application on June 29, 1993, July 27, 1993, and August 31, 1993 : all persons present at the hearing were given an opportunity � to be heard. 4. That the written comments and analysis of the City staff and the Planning Commission were considered. NOW THEREFORE, BE IT RESOLVED that the application for ZN 93-2 is hereby approved based on the following Findings of Fact: 1. That it is appropriate to require religious institutions to be permitted with a conditional use permit in the B-2 and B-3 zoning districts in order to maintain the integrity of these commercial areas, and maintain the health, safety and welfare of the religious institutions, adjacent properties, and the community in general. Adopted this 7th day of September, 1993 . Charles D. Redepenning, Mayor ATTEST: � James A. Genellie, City Clerk ..-� CITY OF HOPKINS Hennepin County, Minnesota ORDINANCE NO 93-725 BE IT ORDAINED by the City Council of the City of Hopkins as follows: That the Hopkins Zoning Ordinance No. 535 be and the same is hereby amended by amending the following sections: 535.01 subd. 3. B-1 B-2 B-3 109. Religious institutions, etc X (2)XDD (2) XDD 535.03 subd. 2 DD DD)Religious Institutions provided: 1. That there shall be no permanent or temporary living units on the property except for the parsonage. 2. That there is adequate screening or buffering provided from abutting residential districts. 3. That there is adequate off-street loading and service entrances as detailed in section ^ 550.09. 4. That there shall be no religious institution within 350 feet of a off sale or on sale liquor establishment. 5. That there shall be no religious institution within 350 feet of an adult oriented business. 6. That the building occupying the religious institution shall meet the building occupancy codes. 7. That a religious institution located in the B-3 district shall comply with the parking requirements of section 550.05. First Reading: September 21, 1993 Second Reading: October 5, 1993 Date of Publication: October 13, 1993 Date Ordinance Takes Effect: November 3, 1993 Charles D. Redepenning, Mayor �-- ATTEST: James A. Genellie, City Clerk \ t Y O G .c� �� ti 5 August 24, 1993 ° P K � � Planning Report ZN93-2 ORDINANCE AMENDMENT- RELIGIOUS INSTITUTIONS Proposed Action. - Staff recommends the following motion: Move to approve Resolution RZ 93-10 recommending approval of Ordinance 93-725 amendin� the Zoning Ordinance to permit religious institutions as a conditional use permit within the B-2 and B-3 zonin� districts Overview. In 1991 a moratorium was placed on permitting churches in the B-2 and B-3 zoning district in order to give the Commission time to review a possible ordinance change. Last October the City Council extended the moratorium until October 1993. The moratorium can be extended for an additional six months At the March Zoning and Planning meeting the Planning Commission reviewed the information provided by the staff and asked the staff to draft an ordinance prohibiting churches in the B-2 and B-3 zoning districts. The staff -�d recommended that religious institutions be regulated by a conditional use permit. After reviewing additional �rmation of prohibiting religious institutions in the business district, it was determined that the elimination of �ciigious institutions in the business district raised some constitutional issues. As a result of reviewing further information, the Commission directed staff to draft an ordinance that would permit religious institutions in the B-2 and B-3 zoning districts with a conditional use permit. With this action a church would need to meet the conditions outlined in the ordinance prior to receiving a permit to locate in the B-2 and B-3 districts. The City Attorney has recommended that if the City desires to eliminate religious institutions from the business districts, a study should be completed to support this decision. Primary Issues to Consider. o Why was the moratorium proposed? o What are the legal issues regarding prohibiting churches in business districts? o Where will religious institutions be allowed if the attached ordinance is adopted? o What is the basis of the staff recommendation? Supqorting DoCuments. o Analysis of Issues o Resolution RZ93-10 o Ordinance 93-725 � �7 -�ancy . Anderson, AICP nner ZN93-2 --� Page 2 Primary Issues to consider. o Why was the moratorium proposed? The moratorium was proposed by staff in order to give the Planning Commission time to review a possible ordinance change which would restrict the location of religious institutions in the B-2 and B-3 districts. These districts are more intense commerciaUretail in nature and there was a concern about the compatibility of religious institutions with the other commercial uses allowed in these districts. The Zoning Ordinance currently al�ows religious institutions as a permitted use in all the residential districts and the business districts. o What are the legal issues regarding prohibiting religious institutions in the business districts? The City Attorney has recommended that if religious institutions are prohibited in the B-2B-3 zoning districts a study should to be completed. The study would need to justify the reasons for eliminating religious institutions in commercial area by detailing the negative impacts they would have in such areas. If religious institutions are excluded from the business districts without any clearly defined reasons the City could be subject to future legal action and the subsequent legal costs from the group bringing the legal action if the City �st the case. ��iere was a recent case in Hastings that is similar to the situation in Hopkins. The facts of the case are as follows: o Cornerstone Bible Church located its church in a commercial zone (C-3) in downtown Hastings. o Churches are not allowed in the C-3 zoning district. o The church requested that the property be rezoned or the Zoning Ordinance amended to allow churches in commercial areas. This request was denied by the City. The Church challenged the City's ordinance of excluding churches from the central business district as a violation of its rights to free speech, freedom of association, free exercise of religion, equal protection and due process. The court decision was in favor of the church. There decision was based on the fact that: "The City has not provided factual support for the assumptions that underlies its exclusion of churches, and the alleged secondary effects of churches on commercial activity remain a disputed factual issue." The court also stated the following regarding the basis for the City denying the churches from the C-3 district. "The City presented affidavits from two city planners containing little more than conclusory statements that excluding churches from the C-3 zone is consistent with the City's planning process and historical land-use." -� Where will churches be allowed if the attached ordinance is adopted? �.eligious institutions will still be allowed in the residential districts and the B-1 business district as a permitted use. In the B-2 and B-3 district they will also still be allowed but will require approval of a conditional use permit. ZN93-2 Page 3 � o What is the basis of the staff recommendation? The staff is recommending that religious institutions are allowed by conditional use permit in the B-2 and B-3 zoning districts. By undertaking this action it will not be necessary for the City to expend time and funds necessary to complete a study to justify this action. Religious uses would remain permitted in the B-2 and B-3 zoning districts with a conditional use permit and therefore there should be no basis for legal action against the City unless an applicant is denied a conditional use permit for reasons which they feel are arbitrary and capricious. Staff is recommending a variety of conditions that religious institutions would need to comply with for approval of a conditional use permit. The conditions are meant to reduce potential negative impacts and insure compatibly of religious institutions with more traditional retail uses being located side by side in these districts. Staff is recommending that churches are allowed in the B-1 district. The B-1 business district is a limited business area, which is not as retail oriented as the B-2 and B-3 districts. Alternatives 1. Recommend approval of Ordinance 93-725. By recommending approval of Ordinance 93-725 the City Council will consider a recommendation of permitting religious institutions in the B2B-3 zoning districts with a conditional use permit. � By recommending denial of the Ordinance 93-725, the City Council will consider a recommendation of denial for allowing religious institutions as a conditional use permit in the B-2 and B-3 zoning districts. The present ordinance would remain in force for religious institutions as a permitted use within all the business districts if the City Council considers this alternative. 3. Continue for further information. If the Commission indicates that further information is needed, the item should be continued. The moratorium will expire in October if the City Council does not extend the moratorium. 4. Recommend that a study is conducted to determine the positive and/or negative affects of religious institutions in commercial areas. If the Commission indicates that a study should be conducted, this item should be continued. �\ ��_ CITY OF HOPKINS Hennepin County, Minnesota ORDINANCE NO 93-725 BE IT ORDAINED by the City Council of the City of Hopkins as follows: That the Hopkins Zoning Ordinance No. 535 be and the same is hereby amended by amending the following sections: 535.01 subd. 3. B-1 B-2 B-3 109. Religious institutions, etc X (2)XDD (2) XDD 535.03 subd. 2 DD DD) Religious Institutions provided: 1. That there shall be no permanent or temporary living units on the property except for the parsonage. 2. That there is adequate screening or buffering provided from abutting residential districts. 3. That there is adequate off-street loading and service entrances as detailed in section � 550.09. 4. That there shall be no religious institution within 350 feet of a off sale or on sale liquor establishment. 5. That there shall be no religious institution within 350 feet of an adult oriented business. 6. That the building occupying the religious institution shall meet the building occupancy codes. 7. That a religious institution located in the B-3 district shall comply with the parking requirements of section 550.05. First Reading: September 7, 1993 Second Reading: September 21, 1993 Date of Publication: September 29, 1993 Date Ordinance Takes Effect: October 19, 1993 Charles D. Redepenning, Mayor � ATTEST: James A. Genellie, City Clerk .�.., CITY OF HOPKINS Hennepin County, Minnesota RESOLUTION NO: RZ93-10 RESOLUTION MAKING FINDINGS OF FACT AND RECOMMENDING APPROVAL OF AN APPLICATION FOR AN ORDINANCE AMENDMENT WHEREAS, an application for an Ordinance Amendment ZN 93-2 made by the City of Hopkins is recommended for approval. WHEREAS, the procedural history of the application is as follows: 1. That an application for an ordinance amendment ZN 93-2 was filed with the City of Hopkins on April 23 , 1993 . 2 . That the Hopkins Planning Commission reviewed such application on June 29, 1993 , July 27, 1993 , and August 31, 1993 . ^ 3 . That the Hopkins Planning Commission, pursuant to published notice, held a public hearing on the application on June 29, 1993 , July 27, 1993 , and August 31, 1993 : all persons present at the hearing were given an opportunity to be heard. 4 . That the written comments and analysis of the City staff and the Planning Commission were considered. NOW THEREFORE, BE IT RESOLVED that the application for ZN 93-2 is hereby recommended for approval based on the following Findings of Fact: 1. That religious institutions will be permitted with a conditional use permit in the B-2 and B-3 zoning districts. Adopted this 31st day of August, 1993 . Patricia M. Reuter, Chairman �. `��� June 21, 1993 ti � Planning Report ZN93-2 � P K � c� �� ZONING AMENDMENT - CHURCHES Proposed Action. Staff recommends the following motion: Move continue the public hearina reqardina reliaious institutions and direct staff to draft an ordinance allowina religious institutions as a conditional use permit in the B-2 and B-3 zoning districts If the Planning Commission determines that religious institutions should not be permitted in the B-2 and B-3 zoning districts the appropriate action is the following: Move to approve Resolution RZ93-10 recommending approval of Ordinance 93-725 prohibiting churches in the B-2 and B-3 zoning districts. Staff is not recommending this action without a study being completed to support this action. overview. In 1991 a moratorium was placed on permitting churches in the B-2 and B-3 zoning districts. Last October the City Council extended the moratorium until October 1993 . At the March Zoning and Planning meeting the Commission reviewed the information provided by the staff and asked the staff to draft an ordinance prohibiting churches in the B-2 and B-3 zoning districts. The staff requested the City Attorney's opinion regarding the elimination of religious institutions in the B-2 and B-3 zoning ^ district. Mr. Miller's opinion is attached. He has recommended that if the City wants to eliminate religious institutions from the business districts, a study should be completed to support this decision. Staff is now recommending that rather than specifically prohibit religious institutions from the B-2/B-3 zoning districts, that they are regulated by a conditional use permit. Primarv Issues to Consider. o Why was the moratorium proposed? o Where are religious institutions currently allowed in the City? o What is the City Attorneys regarding prohibiting churches in the business districts? o Where will religious institutions be allowed if the attached ordinance is adopted? o Why not prohibit religious institutions in the B-1 zoning district? o What was the conclusion in the Hastings case? o What is the basis of the staff recommendation? Suouortinq Documents. o Analysis of Issues o City Attorney's opinion , o Resolution RZ93-10 � o Ordinance 93-725 o Hastings case �r � �t Nanc� S. Anderson� , AICp Plan r ZN93-2 Page 2 �� Primary Issues to consider. o Why was the moratorium proposed? ' The moratorium was proposed because there was interest in putting a church in several locations in the City that were considered prime retail areas. o Where are reliqious institutions currently allowed in the City? The Zoning Ordinance currently allows religious institutions as a permitted use in the residential districts and the business districts. o What is the City Attorney�s reqardinq prohibitinq churches in the business districts? If the Commission wishes to prohibit religious institutions within the B-2 and B-3 zoning districts, the City Attorney has recommended that a study be completed to support the elimination of churches in these zoning districts. The study would need to justify the reasons for eliminating religious institutions in '� commercial area by detailing the negative impacts they would have in such areas. This opinion is also the same as the courts found in the recent court case in Hastings. The City of Hastings did not have any factual basis for denying a church use in the downtown area. The staff checked with the American Planning Association regarding if there have been any studies completed regarding the permitting of religious use in business districts. The information that was sent to the staff from the American Planning Association regarding churches was dealing with excluding churches from residential areas. It appears that including churches in the business districts is an acceptable zoning practice. If the City adopts the attached ordinance without doing a study to support the elimination of religious uses in the business district, �it could open up the City for future legal action. o Where will churches be allowed if the attached ordinance is adopted? Religious institutions will be allowed in ,.the residential districts and the B-1 business district. � � ZN93-2 Page 3 �--� o What was the conclusion in the Hastinqs case? There was a recent case in Hastings that is similar to the situation in Hopkins. The facts of the case are as follows: o Cornerstone Bible Church located its church in a commercial zone (C-3) in downtown Hastings. o Churches are not allowed in the C-3 zoning district. o The church requested that the property be rezoned, this rezoning was denied by the City. The Church challenged the City's policy of excluding churches from the central business district as violative of its rights to free speech, freedom of association, free exercise of religion, equal protection and due process. The court found for the church, and stated the following: "The City has not provided factual support for the assumptions that underlies its exclusion of churches, and the alleged secondary effects of churches on commercial activity remain a disputed factual issue. The court also stated the following regarding the basis for the City denying the churches from the C-3 district. "The City '~ presented affidavits from two city planners containing little more than conclusory statements that excluding churches from the C-3 zone is consistent with the City's planning process and historical land-use" . Attached is the Hastings case. o What is the basis of the staff recommendation? The staff is recommending that religious institutions are allowed by conditional use permit. By undertaking this action the City would not be required to expend time and funds necessary to complete a study to justify this action. Religious uses would remain permitted in the B-2 and B-3 zoning districts with a conditional use permit and therefore there would be no basis for legal action. If religious institutions are excluded from the business districts without a study completed to support this decision the City could be subject to future legal action and the subsequent legal costs from the group bringing the legal action if the City looses the case. Alternatives 1. Recommend approval to continue the public hearing and direct staff to draft an ordinance to permit religious institutions ^ as a conditional use permit. 2 . By recommending approval of the Ordinance 93-727, the City Council will consider a recommendation of approval to prohibit religious institutions in the B-2 and B-3 zoning district. ZN93-2 Page 4 � 3 . Continue for further information. If the Commission indicates that a study should be conducted to determine that religious institutions should be eliminated from the B-2 and B-3 zoning districts this item should be continued. �� �"� �.vi � � ur� �1��s C I T Y O F H O P K I N S February 12, 1993 Nancy Anderson City of Hopkins Dear Ms. Anderson: I have finally been able to plow through the file you gave me on the City of Hastings lawsuit with the Cornerstone Bible Church. The issue in this case was whether Hastings could exclude churches from its C-3 District which was intended to be a zoning classification for a revitalized central business district. Although a complete analysis of all the issues raised in the appeal by the church to the Eighth Circuit Court would be quite lengthy I thinks it suffices to say at this point the city can exclude churches from the commercial business .-, districts if similar uses referred to in the Courts decision sucYi as Alcoholics Anonymous, counseling centers, Masonic lodges, other non-commercial activities are similarly excluded. The exclusions pertaining to churches should be supported by a study that establishes such uses displace potential commercial uses. To support a finding in favor of the City, there must be facts to show the City is justified to disallow churches because such organizations displace economic activity to a greater extent than other non-commercial uses that may be allowed in a business zoned area. It is of particular importance the exclusion be based on a thorough and logically detailed analysis or study upon which the City can rely in excluding churches or any other non-commercial activities wherever it intends to encourage or promote economic vitality consonant with the use of a central business district. � �l ,S�ince�rely, / /,. �� C ��'��% � � � i+�e��A.� Miller . � JAM/lz jj� / / --� % ✓ 1010 First Street South,Hopkins,Minnesota 55343 612/935-8474 An Equal Opportunity Employer ^ CITY OF HOPKINS Hennepin County, Minnesota RESOLUTION NO: RZ93-10 RESOLUTION MAKING FINDINGS OF FACT AND RECOMMENDING APPROVAL OF AN APPLICATION FOR AN ORDINANCE AMENDMENT WHEREAS, an application for an Ordinance Amendment ZN 93-2 made by the City of Hopkins is recommended for approval. WHEREAS, the procedural history of the application is as follows: 1. That an application for an ordinance amendment ZN 93-2 was filed with the City of Hopkins on April 23 , 1993 . 2 . That the Hopkins Planning Commission reviewed such application on June 29, 1993 . 3 . That the Hopkins Planning Commission, pursuant to published ^ notice, held a public hearing on the application on June 29, 1993 : all persons present at the hearing were given an opportunity to be heard. 4 . That the written comments and analysis of the City staff and the Planning Commission were considered. NOW THEREFORE, BE IT RESOLVED that the application for ZN 93-2 is hereby recommended for approval based on the following Findings of Fact: 1. The standards for the B-2 and B-3 zones which regulate density, setbacks, etc. , promote a highly intensive commercial development pattern. Based on these standards churches do not constitute the highest and best use of land which is zoned B-2 and B-3 . 2 . The nature and timing of general church activities is in contrast to the business environment and to the business hours of the downtown. Therefore, no business or retail contribution or activity is generated which is contrary to the intent of the B-2 and B-3 zones and the goals and objectives of the Hopkins Comprehensive Plan and the Strategic Plan for Economic Development. � 3 . The basic purpose of the zoning ordinance is to ensure the public health, safety and general welfare in accordance with the official comprehensive plan of the RESOLUTION NO: RZ93-10 Page 2 --� City of Hopkins, and with adopted development goals, policies and proposals contained therein. Toward this end, the ordinance has divided the City of Hopkins into zoning districts. These districts contain standards which are intended to retain the integrity of residential, commercial and industrial areas. Religious institutions in the B-2 and B-3 zoning districts are not consistent with the intent of the B-2 and B-3 zoning districts. Adopted this 29th day of June, 1993 . John T. Hutchison, Chairman �� � � CITY OF HOPKINS Hennepin County, Minnesota ORDINANCE NO. 93-725 ORDINANCE AMENDING THE ZONING ORDINANCE PROHIBITING RELIGIOUS INSTITUTIONS IN THE B-2 AND B-3 ZONING DISTRICTS BE IT ORDAINED by the City Council of the City of Hopkins as follows: That the Hopkins Zoning Ordinance No 535 be and the same is hereby amended by amending the following section: 535. 01 subd. 3 . B-1 B-2 B-3 109 . Religious institutions, etc. X First Reading: July 6, 1993 Second Reading: July 20, 1993 r._ Date of Publication: July 23, 1993 Date Ordinance Takes Effect: August 17, 1993 Charles D. Redepenning, Mayor ATTEST: James A. Genellie, City Clerk � � United States Court of Appeals ^ FOR THE EIGHTH CIRCUIT No. 90-5347 Cornerstone Bible Church; * James Bzoskie, * * Appellants, * * Appeal from the United States �• * District Court for the * District of Minnesota. City of Hastings, * * Appellee. * Submitted: February 13, 1991 Filed: November 1 , 1991 Before LAY, Chief Judge, McMILLIAN and ARNOLD, Circuit Judges. � LAY, Chief Judge. Cornerstone Bible Church (Church) and its pastor, James Bzoskie, appeal the district court's grant of summary judgment in favor of the City of Hastings, Minnesota. The suit arose from enforcement of a zoning ordinance restricting the location of the Church from the town's central business district. Upon review we affirm in part, reverse in part, and remand for trial. I. The City of Hastings (City) is the second oldest city in the State of Minnesota. Established along the Mississippi River in 1853 , the City's business district developed parallel to the river. Although the City has expanded and now covers more than ten square --� miles, the riverside business district has been preserved and is a significant business area. , In the mid-1970s the City set out to revitalize its central � business district. It developed a Downtown Revitalization Plan designed to preserve and restore the central business district. The goals of the Revitalization Plan are promoted by the City Planning Commission and are enforced under the City's zoning ordinance. The City zoned its central business district commercial (C-3) with the intent of establishing "a community-regional commerce district . . . in recognition of the existing downtown commercial development and of the need for its future expansions, rehabilitation and redevelopment. " Hastings, Minn. , Zoning Ordinance § 10. 17 subd. 1. Permitted land uses in the C-3 zone include commercial establishments, public and semi-public buildings, private clubs, second-floor apartments, parking lots and " [a]ccessory uses incidental to the foregoing principal uses. " Id. at subd. 2 . Uses allowed under special permit include gas stations, drive-in establishments, creameries and small animal � clinics. Section 10. 17 does not mention churches.� �The relevant part of the zoning ordinance reads as follows: Section 10. 17 . C-3 COMMUNITY-REGIONAL COMMERCE SUBD. 1. Intent. The intent of this Chapter in establishing a community-regional commerce district is in recognition of the existing downtown commercial development and of the need for its future expansions, rehabilitation and redevelopment. SUBD. 2 . Uses Permitted A. Commercial establishments including, but not limited to, the following: � (1) Retail establishments such as grocery, hardware, drug, clothing and furniture stores, eating and drinking places, and franchised auto dealers. (2) Personal services such as laundry, barber, shoe repair shop and photography studio. -2- �.... �--. The Cornerstone Bible Church was organized in Hastings in 1983 . The Church first met in Pastor James Bzoskie's home. The congregation quickly outgrew that location and the Church rented space in the local high school. Seeking a permanent home, the Church first purchased property on lOth Street in an industrial zone, making the purchase contingent on City approval of a change (3) Offices: Administrative, executive, professional, medical and research, without merchandisinq services. (4) Finance, insurance and real estate services. (5) Repair services such as jewelry and radio and television repair shops, but not auto repair. (6) Entertainment and amusement services, such as motion picture theatre and bowling alley. ,--_ (7) Lodging services such as hotel and motel. B. Public and semi-public buildings such as post office, fire station and City Hall. C. Private Clubs. D. Apartments provided they are located above the first floor level. E. Automobile parking lots. F. Accessory uses incidental to the foregoing principal uses such as off-street parking and loading areas, signs, storage of merchandise, and wholesaling, when incidental to a permitted use. Subd. 3 . Uses by Special Permit A. Automobile service stations and motor vehicle repair and wash. B. Drive-in establishments. C. Creameries. D. Small animal clinics, excluding establishments with outside � runs and non-patient overnight boarding. -3- in zoning to residential use, which would encompass churches. The City denied the zoning change but the Church went ahead with the purchase. ''" During this time the Church leased the Caturia Building in the central business district and began conducting church activities there. The City notified the Church that it must discontinue using the Caturia Building for church activities. The Church responded by negotiating to purchase a theatre in the central business district. The Church requested the City to amend the zoning ordinance to allow church activities at the theatre. The City denied the request but gave the Church an extension of time to vacate the Caturia Building. The Church then proposed yet another location, at 515 East 3rd Street in an area zoned for industrial use. The City gave preliminary approval to a change in zoning for the site but the Church withdrew its request and requested rezoning of its lOth Street property. The City denied the request and continued to press the Church to leave the Caturia Building. The Church then �"" filed this lawsuit. Although the Church has requested zoning variances or amendments with respect to both industrial and commercial zones, this lawsuit focuses on the City's exclusion of churches from the central business district (C-3) zone. The City Council resolution denying the Church's request to use the Caturia Building expresses the City's rationale for precluding churches from the central business district: The nature and timing of general church activities is in contrast to the business environment and to the business hours of the downtown. Therefore, no business or retail contribution or activity is qenerated which is contrary to the intent of the C-3 zone and the goals and objectives of the Downtown Redevelopment P1an and the Hastings Comprehensive Plan. -4- ...� r Hastings City Council Resolution No. 4-87 (Jan. 5, 1987) . The City Council also found no need to provide space for churches in the central business district because churches are allowed in the residential zones that comprise forty-five percent of the City. Id. The Church challenged the City's policy of excluding churches from the central business district as violative of its rights to free speech, freedom of association, free exercise of religion, equal protection and due process. The district court granted summary judgment for the City on all claims. II. A. FREE SPEECH The Church argues that the City's exclusion of churches from �--� the central business district violates the congregation's rights to free speech. Because the City does not preclude churches entirely, the district court held that the zoning ordinance is properly analyzed as a time, place, and manner restriction. Citv of Renton v. Playtime Theatres Inc. , 475 U.S. 41, 46 (1986) . The court then held that the City's policy was a valid time, place, and manner restriction under the test set out in Ward v. Rock Against Racism, 491 U.S. 781 (1989) . The City allows churches, and by implication organized religious speech, in residential areas but not in the central business district.2 Although the City's stated objective is to ZAlthough exclusion of churches from the central business district is not explicit in the text of the ordinance, the City has unequivocally interpreted the ordinance to exclude churches from the C-3 zone. The district court places much emphasis on the fact that the zoning ordinance does not explicitly exclude churches from the central business district. 740 F. Supp. at 662 . We cannot --� -5- allow uses that generate economic activity, the City has chosen to place determinative weight on the fact that the proposed use is a � church. Thus, the religious content of the applicant's speech can determine whether the City permits it to locate in the C-3 zone.3 The Supreme Court's decisions in Renton and Boos v. Barrv, 485 U.S. 312 (1988) , however, make clear that a restriction of speech should be analyzed as content-based only if the asserted justification for the restriction is content-based. Renton, 475 U.S. at 48; Boos, 485 U.S. at 320-21. "Government regulation of expressive activity is content neutral so long as it is �justified without reference to the content of the regulated speech. "' Ward, 491 U.S. at 791 (quoting Clark v. Community for Creative Non- Violence, 468 U.S. 288, 293 (1984) ) . In Renton, the zoning ordinance restricted the location of adult theatres -- a content- based restriction -- but the City justified its ordinance by asserting that it was concerned only with the secondary effects adult theatres have on the surrounding neighborhood. 475 U.S. at 47. The Court analyzed the Renton ordinance as a time, place, and ,� manner restriction. Id. at 46. The City does not attempt to justify its ordinance as a valid effort to circumscribe religious worship. The City claims to be interested only in the secondary effects of the Church on economic embrace such a distinction. Al1 parties agree that the City enforces its ordinance to exclude churches from the C-3 zone. Thus, it is inconsequential whether that exclusion is explicit or implicit in the ordinance. To hold otherwise would allow governments to evade first amendment scrutiny simply by drafting their laws to restrict speech implicitly rather than explicitly. 3This view of the City's ordinance gains support from the fact that the City has permitted several non-commercial entities to locate in the C-3 zone, including the Masonic Lodge, Alcoholics Anonymous, and Birthright (a pregnancy counseling center) . These organizations do not appear to further the City'� goal of economic vitality any more than the Church, yet only the Church has been excluded. -6- �.�. ^ vitality in the central business district. Although the Church disputes whether economic vitality is the real objective of the ordinance, the City's assertion of a content-neutral justification is sufficient to render the ordinance subject to time, place, and manner analysis. Id.4 In the present case, the C-3 zoning requirements .exclude churches altogether. Thus, we express a lingering doubt as to whether the time, place and manner doctrine applies. However, we construe the overall Hastings zoning ordinance, which makes allowances for churches in residential areas, as simply restrictive and therefore find the time, place, and manner rule applicable. In Renton, adult theatres were not banned altogether but were not allowed "within 1000 feet of any residential zone, single- or multiple-family dwelling, church, park, or school. " Id. at 43. It was on this basis the Court applied the time, place and manner regulation. � Time, Place and Manner. A valid time, place, and manner restriction must (1) be narrowly tailored to serve a significant governmental interest, and (2) leave open ample alternative channels for communication of the information. Ward, 491 U.S. at 791. As the district court observed, zoning in general is a legitimate municipal tool and the City's revit�lization plan is unquestionably a permissible municipal objective. See Renton, 475 U.S. at 50. However, the 4See also L. Tribe, American Constitutional Law § 12-3 , at 795 n.4 (2d ed. 1988) ("' [W]hat sort of regulation it really is' is irrelevant, as well as unintelligible. The critical inquiry is whether the state chooses to (or must) justifv the regulation by reference to dangers that flow from an act's communicative content. " (citation omitted) ) . Practically speaking, it is too difficult to ascertain the City's true purpose if in fact its asserted justification is a pretext. United Stat,es v. O'Brien, 391 U. S. 367 , 383-84 (1968) . ---� -7- question whether the ordinance is narrowly tailored requires more particularized scrutiny. � Although the City is not required to show that its ordinance is the least-restrictive means of accomplishing its objective, Ward, 491 U.S. at 798, the City "may not regulate expression in such a manner that a substantial portion of the burden on speech does not serve to advance its goals. " Id. at 799; see also Renton, 475 U.S. at 51-52 (" [W]hatever evidence the city relies upon [must be] reasonably believed to be relevant to the problem that the city addresses. ") . This places the burden on the City to provide some factual support for its claim that exclusion of churches advances its goal of revitalizing the central business district. The City presented affidavits from two city planners containing little more than conclusory statements that excluding churches from the C-3 zone is consistent with the City's planning process and historical land-use. Church App. at 128-35. The only specific reasons given for excluding churches were that a church �.. would displace potential commercial uses and increase the potential for traffic, parking and land-use conflicts.5 Id. at 133-34. The Church argues that both affidavits should be discounted because the affiants had been on the City payroll and had helped develop the planning policies they were defending. Significantly, the City conceded that it had never conducted any studies of the effects of churches on commercial activity, even though several existing churches border the C-3 zone. Although the City Council resolution stated that " [t]he nature and timing of general church activities is in contrast to the . . . business hours of the downtown, " Hastings City Council Resolution No. 4-87 SThe City concedes that the traffic-related issues are asserted only "in passing" and are "not . . . the keystone of the City's position in this matter. " City Brief at 26. -8- �.. (Jan. 5, 1987) , the City has not supported this statement. Indeed, ^� some of the permitted uses have much the same hours of operation as the Church.6 Moreover, the Church met the City's evidence with affidavits from owners of businesses in the C-3 zone who stated that Cornerstone Bible Church had no negative effects on the central business district. Church A�a. at 54, 59 . In a summary judgment proceeding the court is to view the facts in the light most favorable to the non-moving party. McCuen V. Polk Countv, 893 F.2d 172, 173 (8th Cir. 1990) . The City's affidavits are conclusory and speculative, pointing only to potential secondary effects without the benefit of any study or factual support. Although the Court in Renton held that a city need not conduct new studies if it was relying on relevant studies generated by other cities, it did not eliminate the City's obligation to provide some type of factual support for its alleqation of secondary effects. 475 U.S. at 51. The City has not provided factual support for the assumptions that underlie its ^� exclusion of churches, and the alleged secondary effects of churches on commercial activity remain a disputed factual issue. Thus, we find sununary judgment was inappropriate. Underinclusive Classification The Church claims the ordinance is underinclusive because it excludes non-commercial religious entities but allows other non- commercial entities in the C-3 zone under the provision allowing 6The record indicates that the Church has services on Sunday mornings and evenings, Wednesday evenings, and has bible college on Tuesday evenings. Church App. at 44-45. It is not clear when counseling services and other activities take place. See id. The Veterans of Foreign Wars and the American Legion are open evenings and Sundays. City App. at 129; Church App. at 123•. � _9_ "private clubs. "7 These permitted organizations, including Alcoholics Anonymous, Birthright (a pregnancy couriseling center) , � the American Legion, the Veterans of Foreign Wars and the Masonic Lodge, conceivably displace potential commercial uses just as the Church would, yet the City permits the former in the C-3 zone. Although the Court "frequently has upheld underinclusive classifications on the sound theory that a legislature may deal with one part of a problem without addressing all of it, . . . [t]his presumption of statutory validity . . . has less force when a classification turns on the subject matter of expression. " Erznoznik v. City of Jacksonville, 422 U.S. 205, 215 (1975) . In Erznoznik, the Court invalidated on first amendment grounds an ordinance prohibiting display of films containing nudity at drive- in theatres. The city justified its ordinance as an effort to avoid traffic accidents caused by distracted drivers on streets near the drive-in. Id. at 214 . The Court found this justification insufficient in light of the wide variety of other scenes in movies that also would distract drivers.8 Id. at 214-15. � On the issue of underinclusiveness there are disputed issues of material fact. The Church and City dispute whether the Church's activities are distinguishable in any relevant respect from �See supra note 1. The district court found the City's failure to define the term "private clubs" irrelevant because it was clear that churches were "not subsumed in that definition. " 740 F. Supp. 654, 667 (D. Minn. 1990) . BThe Court also considered an underinclusiveness argument in Renton, 475 U. S. at 52 . The adult theatre owner argued that the Renton ordinance restricting the location of adult theatres was underinclusive because it did not regulate other types of adult business that would generate the same unwanted secondary effects. Id. The Court rejected the challenge because the theatre could not point to any other adult business in Renton that was treated differently than the adult theatres. Id. at 52-53 . In contrast, the Church has identified five non-commercial entities permitted in the C-3 zone. -10- � � permitted non-commercial uses. Although the district court discussed this issue to some degree in evaluating the Church's equal protection claim, 740 F. Supp. at 668, the focus of that analysis was somewhat misplaced. It is not necessary for us to debate the definitions of "church" or "private club, '� nor need we ascertain whether the permitted non-commercial uses are in any way "religious. " Rather, the ordinance must be evaluated solely in light of its purposes. Because the stated objective of the ordinance is to promote economic vitality in the C-3 zone, the ordinance must be upheld or invalidated based on whether the Church's land-use would impede the City�s objective of economic vitality more or less than the permitted uses. The district court did not make any findings concerning the secondary effects of the permitted uses and the Church. However, the Church has established that non-commercial entities currently exist in the C-3 zone.9 On remand the � factfinder should make such findings as will enable it to determine whether exclusion of churches from the C-3 zone is justifiable on the ground that a church displaces economic activity to a greater extent than the non-commercial uses the City has allowed in the zone. B. EOUAL PROTECTION The equal protection clause is "essentially a direction that all persons similarly situated should be treated alike. " City of 9For that matter, it is difficult to imagine how a church would displace commercial activity any more than a second-story apartment, which is permitted in the C-3 zone. A church provides services to members and sometimes may engage in merchandising or quasi-commercial activity. It seems unlikely that any comparable activity would be generated from residences. Although allowing residents in the downtown area may generate demand, parishioners on their way to and from church for meetings, activities, counseling or services likely would also patrbnize the C-3 businesses. � -11- Cleburne v. Cleburne Living Center, Inc. , 473 U.S. 432 , 439 (1985) . The Church's equal protection argument to some degree tracks its free speech claim. It argues that the City excludes the non- ` commercial Church from the C-3 zone but permits other similarly situated non-commercial entities. The district court found the Church not similarly situated to the permitted entities and concluded that any similarities "are not significant for purposes of the ordinance or the equal protection clause. " 740 F. Supp. at 668 . Under the equal protection clause we must consider whether the City has a rational basis to differentiate between the Church and the entities it permits in the C-3 zone. Any differentiation must be relevant to the objectives the City is attempting to achieve through its ordinance. Cleburne, 473 U.S. at 441. In Cleburne, the Court enjoined a city's enforcement of a zoning ordinance that prohibited the placement of a group home for the mentally retarded in a residential area but allowed all other types of residential dwellings. Id. at 450. The Court's analysis focused on whether the group home "would threaten legitimate interests of the city in a �"' way that other permitted uses such as boarding houses and hospitals would not. " Id. at 448. The present case requires similar analysis, and there is no indication in the record that the district court made this vital inquiry. The City implies that it has no choice but to locate the American Legion and the Veterans of Foreign Wars in the C-3 zone because these organizations have liquor licenses and state law prohibits liquor establishments in residential areas. However, while adherence to state law would likely be deemed a legitimate justification for treating similarly situated entities differently, 10 this explanation could not possibly justify allowing 10We do not decide whether the City in fact �.s compelled under state law to locate liquor establishments in the C-3 zone. -12- .� ^ groups such as Alcoholics Anonymous in the C-3 zone. �� Alcoholics Anonymous and the Masonic Lodge do not hold liquor licenses and their internal by-laws prohibit them from obtaining a license, yet theirs are permitted uses. The City offers no other justification for its distinction between churches and other non-commercial entities. 12 The Church has placed the City's rationale for excluding churches at issue. The City is excluding the Church because it will not generate economic activity, but the Church has established a relevant similarity between itself and permitted non-commercial entities. It now is incumbent on the City to provide the rational basis for this apparent unequal treatment of similarly situated entities. The City has failed to support its exclusion of the Church with any justification beyond the conclusory statements in the affidavits of the city planners. Church Atip at 128-35. Thus, summary judgment was not appropriate and the district court on � remand should determine whether the City has a rational basis for treating the Church differently from the permitted entities.13 ��The City implies that it allows non-commercial entities in the C-3 zone if they are eligible for a liquor license. Citv Brief at 24. If this is the City's distinction it is unavailing, for the Church too is eligible for a liquor license. 12The City does offer the tautological argument that Birthriqht and Alcoholics Anonymous are allowed in the C-3 zone because they fall under the category of "professional and medical services. " City Brief at 25. It is meaningless to argue that a land-use is allowed under the ordinance because the ordinance allows it. For equal protection analysis the relevant inquiry is whether allowing one non-commercial entity but excluding another is rational in light of the purposes of the ordinance. Thus, the issue is whether Birthright and Alcoholics Anonymous generate economic activity more or less than the Church. 13The Church claims the City's rationale for treating churches differently from other non-commercial entities should be subject to strict scrutiny. Although courts typically give broad latitude to legislative initiatives concerning economic regulation, New Orleans v. Duke, 427 U.S. 297, 303 (1976) (per curiam) , the Church relies on the statement in Cleburne that a heightened standard of � -13- C. FREE EXERCISE � The Church argues the zoning ordinance violates its first amendment right to free exercise of religion in two ways: the ordinance directly regulates religious worship and also infringes on its "hybrid rights" to free speech and religion. The Church's claims thus follow the two remaining paths for advancing a free exercise claim after the Court's decision in Employment Div. , Dep't of Human Servs. v. Smith, 110 S. Ct. 1595 (1990) . In Smith, the Court held that a neutral law of general applicability that incidentally impinges on religious practice will not be subject to attack under the free exercise clause. Id. at 1600. However, the Court left open the viability of free exercise attacks on government actions that directly regulate religious belief or religious-based conduct, id. at 1599, or that violate the first amendment in conjunction with other constitutional protections. Id. at 1601. � The ordinance has no impact on religious belief and should not review is required "when state laws impinge on personal rights protected by the Constitution. " 473 U.S. at 440. However, in an analogous circumstance of racial discrimination in which plaintiffs sought strict scrutiny the Court stated that "our cases have not embraced the proposition that a law or other official act, without regard to whether it reflects a racially discriminatory purpose, is unconstitutional solelv because it has a racially disproportionate impact. " Washington v. Davis, 426 U.S. 229, 239 (1976) . Absent evidence of purposeful discrimination based on religious status, the rational basis standard should apply. The disparate impact of the ordinance on the Church is insufficient to support an inference of discriminatory purpose, see Davis, 426 U.S. at 242 ; see also Williams v. Anderson, 562 F.2d 1081, 1087 (8th Cir. 1977) , particularly in light of the �ity's efforts to accommodate the Church. -14- � �-- be construed as directly regulating religious-based conduct. 14 The ordinance is a general law that applies to all land-use in Hastinqs. There is no evidence that the City has an anti-religious purpose in enforcing the ordinance. 15 Absent evidence of the City's intent to regulate religious worship, the ordinance is properly viewed as a neutral law of general applicability and under Smith summary judgment on this free exercise claim was appropriate. �b 14The cases cited by the Church are relevant factually but all were decided prior to Smith. See Islamic Center of Mississippi Inc. v. City of Starkville, 840 F.2d 293 (5th Cir. 1988) ; Messiah Batitist Church v. County of Jefferson, 859 F. 2d 820 (lOth Cir. 1988) , cert. denied, 490 U.S. 1005 (1989) ; Lakewood, Ohio Conqreaation of Jehovah�s Witnesses v. City of Lakewood, 699 F.2d 303 (6th Cir. ) , cert. denied, 464 U.S. 815 (1983) ; Grosz v. Citv of Miami Beach, 721 F.2d 729 (llth Cir. 1983) , cert. denied, 469 U.S. 827 (1984) . In any event, the courts upheld the zoninq ordinances in three of the four cases. In the other case the city had permitted twenty-five Christian churches in an area but prohibited a Muslim mosque. Islamic Center, 840 F.2d at 297. The court accordingly found that the ordinance as enforced was discriminatory against Muslims and violated their free exercise '� rights. Id. at 302-03. The facts of Islamic Center go well beyond the present case. �SIndeed, the City has attempted to accommodate the Church by indicating its approval of a zoning change for the Church's property on Third Street. The City also has granted the Church a number of extensions of time to find another location. t6This result is consistent with a recent Second Circuit case involving enforcement of an historic preservation ordinance to restrict a church's right to develop its property. Rector, Wardens & Members of Vestrv of St Bartholomew's Church v City of New York, 914 F. 2d 348 (2d Cir. 1990j , cert. denied, ili S. Ct. 1103 (1991) . St. Bartholomew's Church owned a seven-story building in the heart of Manhattan that was designated an historical landmark under a city ordinance. The church wanted to tear down the landmark and build an office tower to further its charitable and ministerial program, but the city refused permission. The church filed suit claiming, inter alia, that the ordinance violated its rights under the free exercise clause. The Second Circuit applied Smith and found the landmark ordinance a neutral regulation of general applicability. Id. at 355. Although the ordinance "drastically restricted the Church's ability to raise revenues" and despite the fact that approximately ^fifteen percent of all designated landmarks were churches, the -15- The Church also bases its free exercise challenge on the fact � that the ordinance violates the congregation's free speech and equal protection rights along with its free exercise rights. The Supreme Court in Smith observed that " [t]he only decisions in which we have held that the First Amendment bars application of a neutral, generally applicable law to religiously motivated action have involved not the Free Exercise Clause alone, but the Free Exercise Clause in conjunction with other constitutional protections, such as freedom of speech and of the press . . . . " 110 S. Ct. at 1601. The district court rejected this "hybrid rights" claim in light of its grant of summary judgment to the City on the Church's free speech, freedom of association, equal protection, and due process claims. Our reversal of the summary judgment orders breathes life back into the Church's "hybrid rights" claim; thus, the district court should consider this claim on remand. D. DUE PROCESS �-- The Church contends the City's zoning ordinance is unduly vague, leaving its interpretation to the "unbridled discretion" of the city planner.�� The alleged flaw in the ordinance is its failure to define terms such as "church, " "private club, " and "economic activity, " which serve to identify permitted and excluded court found no evidence of an intent to discriminate against religious worship. Id. at 354-55. The Second Circuit concluded that "no First Amendment violation has occurred absent a showing of discriminatory motive, coercion in religious practice or the Church's inability to carry out its religious mission in its existing facilities. " Id. at 355. ��Before the district court the Church also claimed that the city planner's decisions were not subject to meaningful review, but the Church does not press this contention on appeal. Clearly the Church has exercised its ability to appeal the city planner's decisions to the City Council. -16- � � uses. The Church relies entirely on a statement in Gravned v. Citv of Rockford, 408 U.S. 104 (1972) , in which the Court identified three important values offended by vague laws. The Grayned Court stated that a vague law fails to provide citizens reasonable notice of what the law prohibits and allows, and thus will "trap the innocent by not providing fair warning. " Id. at 108. The Hastings zoning ordinance is not such a trap. The ordinance is specific in listing seven broad categories of permitted uses and more than thirty examples. It explicitly indicates where churches are allowed and although it does not explicitly prohibit churches in the C-3 zone, that prohibition is reasonably implied by the omission of churches as a permitted use. The second concern articulated in Grayned was that a vague law "impermissibly delegates basic policy matters to policemen, judges, and juries for resolution on an ad hoc and subjective basis, with ^ the attendant dangers of arbitrary and discriminatory application. " Id. at 108-09 . In the present case the City Council has made the basic policy decisions and has essentially left only the mechanics to the city planner. The City Council has established the zoning policy and objectives for each zone and has enumerated a comprehensive list of permitted uses in the C-3 zone. No legislative body developing a zoning plan could be expected to envision every potential land-use, and it is quite plausible that the Council did not foresee the possibility that a church would seek to locate in a storefront in the central business district. The resulting gap in the ordinance has been interpreted by the city planner in light of the overall objectives for the C-3 zone. The City's statement of objectives, along with available review procedures, sufficiently constrains the city planner's discretion.18 18To the extent that the Church claims that the city planner has discriminated against religious expression, that argument is more appropriately considered as part of the • Church's equal protection claim. As we observed in remanding the Church's equal -17- The third concern of the GraYned Court was that "where a vague � statute 'abut[s] upon sensitive areas of basic First Amendment freedoms, "' it chills First Amendment activity by causing citizens to "'steer far wider of the unlawful zone' . . . than if the boundaries of the forbidden areas were clearly marked. " Id. at 109. Although first amendment freedoms are implicated here, there is no serious risk of chilling religious activity. The ordinance is not vague and has only a tangential effect on religion. Having addressed all the due process concerns raised by the Church and finding them unfounded, we affirm the district court's grant of summary judgment in favor of the City on this claim. SUMMARY The district court's order of summary judgment with respect to the Church's free speech and equal protection claims is reversed and remanded for trial. The order of summary judgment with respect — to the Church's free exercise claim is affirmed except for the "hybrid rights" claim, which is reversed and remanded for further consideration. The order of summary judgment with respect to the protection claim, the City has some way to go in providing a rationale for its distinction between the permitted non-commercial uses and the Church. However, any improper discrimination resultinq from the City's enforcement of the ordinance is not due to a vagueness problem in the text of the ordinance. The text is reasonably and concisely drafted and is not vague. The terms "church, " "private club, " and "economic activity" are familiar terms from common experience and are not unduly ambiguous. Thus, if the ordinance is invalidated it will be because of the assumptions the City has made about the specific land-uses at issue, not because of inherent problems in the text of the ordinance. -18- � Church's due process claim is affirmed. 19 �--- A true copy. Attest: CLERK, U.S. COURT OF APPEALS, EIGHTH CIRCUIT. �. � 19Despite a passing reference in its brief to its freedom of association claim, Church Brief at 36 n.95, the Church has not raised on appeal the district court's grant of summary judgment for the City on its freedom of association claim. � -19- � t Y O G �` i� August 15, 1991 .y 5 Council Report 91-177 � P K � t� MORATORIUM - RELIGIOUS INSTITUTIONS Proposed Action. Staff recommends approval of the following motion: Move to approve Resolution 91-107 approving Ordinance 91-693 for first reading establishing a moratorium on religious uses in the B-2 and B-3 districts. Overview. On July 30, 1991 the Zoning and Planning Commission recommended to the City Council to adopt a interim ordinance placing a moratorium on permitting religious institutions in the B-2 and B-3 zoning districts. Currently religious institutions are allowed as a permitted use in all the business districts. The Commission was concerned with religious institutions occupying buildings in the B-2 and B- 3 districts. Recently interest has been expressed by a church to locate in the Hopkins House which is in a B-3 zone. --� The old Medalist Sports Club is in the process of being rezoned to B-1 and will not be affected by this moratorium. Religious institutions are also allowed in all residential districts with a conditional use permit. This moratorium will not affect any religious use wanting to locate in a residential district. Primary Issues to Consider. o How long should this moratorium last? o Why have a moratorium for religious uses in the B-2 and B-3 districts? o What is the difference in the B-1, B-2 , and B-3 districts? supporting Documents. o Analysis of Issues o Zoning Map o Zoning Ordinance o Resolution 91-107 o Ordinance 91-693 � � � '"'� Nanc S. Anderso Planner � CR 91-107 Page 2 Primary Issues to Consider. o How lonq should the moratoriwn last? Staff is recommending that the moratorium last a year or until an ordinance is enacted. It is not intended that the moratorium will last a year. However, six months probably is not enough time for an ordinance change because the Planning Commission only meets once a month. o Why have a moratorium for reliqious uses in the B-2 and B-3 districts? The existing ordinance allows religious institutions in the B-1, B-2 and B-3 zoning districts. Religious institutions are becoming less traditional in their locations and are moving into locations that in the past usually would not be used for a religious use. This moratorium will give the Planning Commission time to review the existing ordinance and determine if religious institutions should continue to be a permitted use in the B-2 and B-3 zoning districts. The � outcome of the moratorium may be to leave the ordinance as it is. o What is the difference between the B-1, B-2 and B-3 districts? The difference in the business districts is in the uses that are allowed. The B-1 district is a limited business � district, the least amount of uses are allowed in this district. The B-2 district is only the downtown area. The B-3 district is the general business district area which allows most business uses. Alternatives. 1. Approve the ordinance to place a moratorium on religious institutions in the B-2 and B-3 zoning districts. By approving Ordinance 91-693 religious institutions will not be allowed in the B-2 and B-3 districts. 2 . Deny the ordinance to place a moratorium on religious institutions in the B-2 and B-3 zoning districts. By denying the Ordinance 91-693 , the existing ordinance will remain the same which allows religious institutions in the B-2 and B-3 districts. —, 3 . Continue for further information. If the Council indicates that further information is needed, the item should be continued. � CITY OF HOPKINS Hennepin County, Minnesota ORDINANCE N0:91-693 AN ORDINANCE ESTABLISHING A MORATORIUM ON RELIGIOUS INSTITUTIONS IN THE B-2 AND B-3 ZONING DISTRICTS WHEREAS, the City of Hopkins has adopted Ordinance No. 515-570 approving a zoning ordinance. WHEREAS, it has been determined that it is necessary for the health, safety, and welfare of the residents of the City of Hopkins to study and consider an amendment to this ordinance regarding religious institutions in the B-2 and B- 3 zoning districts. WHEREAS, Minnesota State Statues 462 . 355 subd. 4 allows a city to adopt an interim ordinance when undertaking study to revise the zoning ordinance by amendment. NOW THEREFORE, BE IT ORDAINED by the City of Hopkins, Minnesota, Effective upon adoption of this ordinance, a moratorium -� shall be imposed upon the approval of all religious institutions in the B-2 and B-3 zoning districts. This moratorium shall be for the purpose of allowing the City of Hopkins to study and consider an amendment to the zoning ordinance regarding religious institutions in the B-2 and B-3 zoning districts and shall expire October 8, 1992 or upon the enactment of a zoning amendment concerning this matter, whichever comes first. First Reading: August 20, 1991 Second Reading: September 3, 1991 Date of Publication: September 18, 1991 Date Ordinance is Effective: October 8, 1991 Nelson W. Berg, Mayor ATTEST: James A. Genellie, City Clerk ^ •�-.. CITY OF HOPKINS Hennepin County, Minnesota RESOLUTION NO. 91-107 A RESOLUTION ESTABLISHING A MORATORIUM ON RELIGIOUS INSTITUTIONS IN THE B-2 AND B-3 ZONING DISTRICTS. WHEREAS, the City of Hopkins, has adopted Ordinance No. 515-570 approving a zoning ordinance, and WHEREAS, the City has received several inquires regarding locating religious institutions in the B-2 and B-3 districts in the City of Hopkins; and WHEREAS, the City Council has concerns regarding the ability for the City's existing code to adequately regulate religious institutions in the B-2 and B-3 zoning districts in the City of Hopkins and protect the public health, safety and welfare; WHEREAS, it has been determined necessary, to protect the public health, safety and welfare, to establish a moratorium to allow the City of Hopkins to study issues pertaining to religious institutions in the B-2 and B-3 r zoning districts and possible amendments to the City Code to better regulate said religious institutions. NOW THEREFORE, BE IT RESOLVED, that a moratorium prohibiting the use of religious institutions in the B-2 and B-3 districts is approved. Said moratorium shall extend until October 8, 1992 or upon the enactment of a zoning amendment concerning this matter, whichever comes first. BE IT FURTHER RESOLVED, City Council adopts an interim Ordinance 91-693 conforming in all respects to the moratorium adopted by this resolution. Passed and adopted by the Council of the City of Hopkins, Minnesota at a regular meeting held the 20th day of August, 1991. JAMES A. GENELLIE NELSON W. BERG City Clerk Mayor JERRE MILLER City Attorney �"`