Summary
The United States District Court for the Western District of Pennsylvania denied Holy Trinity Ukrainian Catholic Church’s motion for a preliminary injunction against Collier Township and related defendants. The court held that Holy Trinity had not shown a substantial likelihood of success on its claims under the Religious Land Use and Institutionalized Persons Act or the Free Exercise Clause, and that the remaining preliminary-injunction factors also weighed against relief. The court further concluded that the requested injunction was overly broad and would prematurely resolve issues reserved for trial.
Topics
Practice areas
Questions Presented
- Whether Holy Trinity was entitled to a preliminary injunction based on its RLUIPA equal-terms and substantial-burden claims and its Free Exercise Clause claim.
- Whether Holy Trinity satisfied the heightened standard for mandatory preliminary injunctive relief that would require affirmative governmental action and alter the status quo.
- Whether the requested injunction was sufficiently specific and feasible under Federal Rule of Civil Procedure 65(d).
- Whether the remaining preliminary-injunction factors—irreparable harm, relative harms, and public interest—weighed in favor of relief.
Holdings
- Holy Trinity was not entitled to a preliminary injunction because it failed to show a substantial likelihood of success on its RLUIPA or Free Exercise claims and therefore failed to show that its right to relief was indisputably clear.
- Even assuming Holy Trinity could show a likelihood of success, the remaining preliminary-injunction factors weighed against granting relief.
- The requested injunction was impermissibly broad and vague, and the court could not feasibly fashion an order specifying the conduct required or prohibited.
Key quotations
“A preliminary injunction is an extraordinary remedy never awarded as of right.” (II)
“Holy Trinity cannot establish that its right to relief on its RLUIPA or Free Exercise Clause claims, which are the only claims providing the basis for the preliminary injunction, is indisputably clear.” (III.A)
“The Third Circuit has recently affirmed that preliminary injunctive relief “is proper only in the rare case when a preliminary injunction is necessary to preserve the effectiveness of the ordinary adjudicatory process.”” (III.C)
“For the foregoing reasons, IT IS HEREBY ORDERED that Holy Trinity’s Motion for Preliminary Injunction, ECF No. 2, is DENIED.” (IV)
Factual background
Holy Trinity owns approximately 40.6 acres in Collier Township, Pennsylvania, with portions in the Township's R-1 and Planned Economic Development zoning districts. It proposed the Shrine Project, a large religious and cultural complex including a shrine, museum, retreat center, bell tower, parking garage, and related facilities, and sought amendments to the Township's zoning ordinance and map to permit the project. The Township Board denied the Shrine Project proposal in September 2024; Holy Trinity later pursued a scaled-down Chapel Project, received conditional approval, and withdrew its state-court appeal. Holy Trinity then filed this federal action and sought an injunction requiring the Township to cease enforcing its zoning ordinances in a manner that would preclude the Shrine Project.
Procedural history
Holy Trinity filed the federal action and motion for preliminary injunction on January 7, 2026. The court permitted limited expedited discovery and held an evidentiary hearing on March 23, 2026. The court denied the motion, concluding that Holy Trinity had not shown a substantial likelihood of success or an indisputably clear right to mandatory relief, and that the remaining preliminary-injunction factors also weighed against relief.