Inclusive Louisiana v. St. James Parish

ELR Citation: 55 ELR 20048
No(s). 23-30908 (5th Cir. Apr 9, 2025)

The Fifth Circuit reversed a district court's dismissal of a discrimination challenge brought against St. James Parish in Louisiana. Two faith- and community-based groups argued the Parish had discriminated against them by directing hazardous industrial facility development toward majority-Black districts and Black churches where their members live; they brought seven claims for violations of their constitutional and statutory civil rights. The district court dismissed the suit for lack of standing and failure to state a claim. The appellate court found that because the groups alleged acts that fell within the applicable limitations periods, their claims under the U.S. Constitution and Religious Land Use and Institutionalized Persons Act (RLUIPA) were not time-barred, and the district court erred in dismissing them for failure to state a claim on statute of limitations grounds. It also found that because the groups' alleged injuries were not merely related to physical access and were traceable to the Parish's conduct, the district court improperly dismissed the groups' claims concerning the RLUIPA and the Louisiana Constitution for lack of standing. The court reversed and remanded for further proceedings.

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