Page 33


MMHT’s free exercise rights are protected from arbitrary discrimination under

the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. 160.

The Supreme Court has recognized successful equal protection claims brought by

a “class of one,” where the plaintiff alleges that she has been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment. Willowbrook v. Olech, 528 U.S. 562, 564 (2000); see also World Outreach Conf. Ctr. v. City of Chicago, 591 F.3d 531, 538 (7th Cir. 2009). 161.

Defendant has applied an arbitrary set of standards to MMHT that are not found

in the UDO or other codified law in finding that MMHT is not a religious institution and that Maum is not a religion and therefore that MMHT cannot use its Property in the Estate (E) zone as a permitted use, like other religious institutions are permitted to do. 162.

The only reason that MMHT is being treated differently is the content of its

expression. 163.

There is no compelling interest in preventing MMHT from using the Property

based on an arbitrary decision that Maum Meditation is not a religion. WHEREFORE, the Church respectfully prays that the Court grant the relief set forth in the Prayer for Relief. COUNT V: VIOLATIONS OF THE DUE PROCESS CLAUSE OF THE FOURTEENTH AMENDMENT OF THE UNITED STATES CONSTITUTION (AS APPLIED) 164.

The allegations contained in all preceding paragraphs are incorporated here by

reference. 165.

The Fourteenth Amendment provides that no person shall be deprived of “life,

liberty, or property, without due process of law.”


Maum Meditation Center Case  

Federal Court Order Allows Maum Meditation Center In Lake Forest Mansion (Lake Forest, IL – June, 2013) Fourteen days after Maum Meditation...

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