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Protestors gathered outside a meeting of the Manhattan Community Board 1 in mid-August 2010. The board was holding a public-comment period followed by a vote on the contentious Ground Zero mosque, otherwise known as Park51. The proposed development included a thirteen-story Muslim cultural center housing, among other uses, a mosque and an auditorium. Burlington Coat Factory abandoned the building shortly after September 11, 2001 when the landing gear from a plane that struck a World Trade Center tower crashed through its roof. “You’re building over a Christian cemetery!” one sign read. A supporter of the Muslim center countered, “I say bring it on. What a wonderful opportunity to teach tolerance.” In the end, the board had no choice but to approve the proposal. A few weeks earlier, with the Statue of Liberty serving as his backdrop, New York City Mayor Michael Bloomberg praised another local body, the Landmarks Preservation Commission, for allowing the project to advance saying that “we would betray our values if we were to treat Muslims differently than anyone else.” Among signs that read

RLUIPA's Equal-Terms Provision's Troubling Definition of Equal: Why the Equal-Terms Provision Must Be Interpreted Narrowly