Years ago Willie Nelson sang that Georgia was on his mind. (Is the tune in your head yet?) Well, here at the Religion Law Quiz we’ve had zoning on our mind last week and this week. Let’s see how you do on today’s Quiz.
A religious ministry provides faith-based transitional housing to formerly incarcerated people some of whom have committed sex offenses involving minor children. The city’s local ordinance prohibits some registered sex offenders from living within 2,000 feet of places where kids typically gather. The ministry argues in court that the city’s ordinance threatens its ability to carry out its faith-based mission. Who wins under these circumstances? The city or the ministry?
(Scroll down for the answer)
Answer: The city. Hope Prison Ministries v. City of Fort Worth, Texas, No. 4:26-CV-00369-P, 2026 WL 2364722, at *1 (N.D. Tex. Aug. 14, 2026). Here is an A.I. generated summary of the decision:
Hope Prison Ministries sued the City of Fort Worth after the City enacted an ordinance prohibiting certain registered sex offenders—those whose offenses involved minor victims—from living within 2,000 feet of places where children commonly gather. Hope Prison Ministries, a faith-based organization providing transitional housing and Christ-centered rehabilitation to formerly incarcerated people, argued that the ordinance threatened its ability to carry out its religious mission by preventing it from housing some of the people it serves.
The religious freedom issues centered on three claims: the First Amendment Free Exercise Clause, the Religious Land Use and Institutionalized Persons Act (RLUIPA), and the Texas Religious Freedom Restoration Act (TRFRA). On the Free Exercise claim, the court held that the ordinance was neutral and generally applicable because it did not target religion, religious organizations, or religious conduct. Instead, the court viewed the ordinance as a public-safety measure aimed at protecting children from potential abuse or predatory behavior. Because the law applied equally to religious and secular housing providers, the court applied rational-basis review rather than strict scrutiny.
Under rational-basis review, the court found the ordinance plausibly related to a legitimate governmental interest: protecting children. The court emphasized that religiously motivated conduct may still be regulated when the regulation protects public health, safety, or welfare. Although the ordinance may incidentally burden Hope Prison Ministries’ religious mission, the court concluded that this incidental burden did not make the ordinance unconstitutional under the Free Exercise Clause.
The court also dismissed the RLUIPA claim, reasoning that the ordinance was not a “land use regulation” within the meaning of RLUIPA. Although the ordinance affects where certain people may reside, the court characterized it as person-based rather than a zoning or landmarking law regulating land use.
Finally, because all federal claims were dismissed, the court declined to exercise supplemental jurisdiction over the state-law TRFRA claim. The City’s motion to dismiss was granted, and the case was dismissed with prejudice.
Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.