In Citizens United to Protect Our Neighborhoods, et al., v. Village of Chestnut Ridge, the U.S. Court of Appeals for the Second Circuit considered whether the district court properly dismissed plaintiffs’ complaint for lack of subject matter jurisdiction on the basis that plaintiffs lacked constitutional standing. – F.4th –, 2024 WL 1471268 (2d Cir. April 5, 2024).

Plaintiffs, three individuals (the individual plaintiffs) who are residents of the defendant Village of Chestnut Ridge (the Village), and a civic organization of which the individual plaintiffs are members, called Citizens United to Protect Our Neighborhoods (CUPON), argued that the Village’s new zoning law relating to places of worship violated the Establishment Clause. Specifically, plaintiffs asserted that the amended zoning laws—aimed at making it easier to build places of worship in Village neighborhoods—impermissibly promoted and endorsed religious uses over secular uses within the Village.