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MMHT is a religious institution under the definition of UDO. Nonetheless, the

County has required MMHT to seek its approval and in doing so has created unnecessary delay, uncertainty, and expense and has prevented MMHT from using the property for its religious purpose. The County has no legal basis for requiring MMHT to seek its approval to use its property. 167.

The County’s attempt to use standards not found in the UDO or any of its codes,

including creating arbitrary standards for defining a community service use and determining the definition of religion, violate MMHT’s due process rights. WHEREFORE, the Church respectfully prays that the Court grant the relief set forth in the Prayer for Relief. COUNT VI: VIOLATIONS OF FREE SPEECH AND FREE ASSOCIATION UNDER THE FIRST AMENDMENT UNITED STATES CONSTITUTION AND ARTICLE I, SECTION 4 OF THE ILLINOIS CONSTITUTION (AS APPLIED) 168.

The allegations contained in all preceding paragraphs are incorporated here by

reference. 169.

MMHT’s religious speech activities, including meditation in community groups,

are protected under the Free Speech Clause of the First Amendment to the United States Constitution and Article I, Section 4 of the Illinois Constitution. 170.

In preventing MMHT from using its Property for such activities, the County has

restricted MMHT’s free speech and association rights. 171.

The County has made a content-based determination that MMHT’s speech is not

permitted, and has applied an arbitrary standard to MMHT that is not applied to other religious institutions.


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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