MMHT’s religious exercise is fully protected by the First and Fourteenth
Amendments to the United States Constitution. 122.
Concomitantly, the use of the UDO to deny MMHT access to the Property to
engage in its religious exercise above infringes upon and burdens the freedom of the congregation under the First Amendment and the Fourteenth Amendment to the United States Constitution, and RLUIPA. 123.
“The loss of First Amendment freedoms, for even minimal periods of time,
unquestionably constitutes irreparable injury.” Elrod v. Burns, 427 U.S. 347, 373 (1976). 124.
Plaintiffs have no adequate or speedy remedy at law to correct or redress the
deprivations of their constitutional and civil rights which continue to be violated because MMHT cannot use the Property for religious exercise. 125.
The Defendant City will suffer no harm if the injunctive relief is granted.
The harm to the Plaintiffs far outweighs any harm to the Defendant, and the
public interest is benefited when constitutional and civil rights are protected. COUNT I: VIOLATIONS OF FREE EXERCISE OF RELIGION UNDER THE FIRST AMENDMENT OF THE UNITED STATES CONSTITUTION AND ARTICLE I, SECTION 3 OF THE ILLINOIS CONSTITUTION (AS APPLIED) 127.
The allegations contained in all preceding paragraphs are incorporated here by
The First Amendment’s protection afforded to religious belief and religious
activity applies to Maum Meditation and MMHT. Church of Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520, 531 (1993) (“religious beliefs need not be acceptable, logical, consistent, or comprehensible to others in order to merit First Amendment protection”); see also Malnak v. Yogi, 592 F.2d 197 (3d. Cir. 1979) (finding that the First Amendment’s definition of religion
Published on Jun 17, 2013
Federal Court Order Allows Maum Meditation Center In Lake Forest Mansion (Lake Forest, IL – June, 2013) Fourteen days after Maum Meditation...