Ninth Circuit Upholds RLUIPA

In Guru Nanak Sikh Society v. County of Sutter, the Ninth Circuit held that the Religious Land Use Freedom and Institutionalized Persons Act of 2000 was a valid exercises of Congress's enforcement power under section 5 of the Fourteenth Amendment.  The court reasoned that RLUIPA was constitutional "because it addresses documented unconstitutional government actions in a proportional manner."