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CASTLE HILLS FIRST BAPTIST CHURCH v CASTLE HILLS TX Click to find out why . . .


Keywords & Phrases
CaseNo: CHFBCVCHT260192, CourtName: MISC 2, Plaintiff: CASTLE HILLS FIRST BAPTIST CHURCH, State: TX Texas, UniqueCaseRef: LCD>CHFBCVCHT260192, City, Church, Castle Hills, Texas, Permit, Act, City Council, Parking, San, Antonio, Zoning Commission, Relief, Winston Properties, City Council Meeting, United States Constitution, Bexar County, Religious Land, United States, Applications, Amended Original Petition, Declaratory, Settlement Agreement, Discriminating, Deprive Plaintiff, Neighborhood, Violation, Reference , ContentID: 120252664

Case Documents
1   Government Exhibit # 2ND AMENDED PETITION
[ see first page and extracted highlights below  ] ItemID: 127720 		32 pages
PDF
Total Documents: 1 document , 32 pages
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1 . Government Exhibit # 2ND AMENDED PETITION

EXTRACTED KEY WORDS 
CHURCH
CASTLE HILLS
PLAINTIFF
TEXAS
DEFENDANT
PERMIT
ACT
CITY COUNCIL
COURT
PARKING
SAN
ANTONIO
ZONING COMMISSION
RELIEF
WINSTON PROPERTIES
CITY COUNCIL MEETING
UNITED STATES CONSTITUTION
BEXAR COUNTY
RELIGIOUS LAND
UNITED STATES
APPLICATIONS
AMENDED ORIGINAL PETITION
DECLARATORY
SETTLEMENT AGREEMENT
DISCRIMINATING
DEPRIVE PLAINTIFF
NEIGHBORHOOD
VIOLATION
REFERENCE

                                             NO. 99-CI-14880

CASTLE HILLS FIRST BAPTIST CHURCH,                     §               IN THE DISTRICT COURT

          Plaintiff,

v.                                                     §               37TH JUDICIAL DISTRICT

THE CITY OF CASTLE HILLS,

          Defendant.
                             §  BEXAR
                                                                                 COUNTY,
                                                                                             TEXAS



                   PLAINTIFF'S SECOND AMENDED ORIGINAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT:

          Plaintiff, CASTLE HILLS FIRST BAPTIST CHURCH (the "Church"), files this Second

Amended Original Petition against Defendant, THE CITY OF CASTLE HILLS (the "City"), and, in

support hereof, respectfully shows the Court the following:

                                              DISCOVERY

          1.      Plaintiff intends for discovery to be conducted under Level 3 of the Texas Rules

Civil Procedure.

                                                PARTIES

          2.      Plaintiff, CASTLE HILLS FIRST BAPTIST CHURCH, is a non-profit corporation

organized and existing under the laws of the state of Texas with its principal place of business in

Antonio, Bexar County, Texas.

          3.      Defendant, the CITY OF CASTLE HILLS, is a Type A municipality of the State of

Texas and is located in Bexar County.  The CITY has previously answered and appeared herein.
SNIPPETS:
  • PLAINTIFF'S SECOND AMENDED ORIGINAL PETITION
  • TO THE HONORABLE JUDGE OF SAID COURT:
  • Plaintiff, CASTLE HILLS FIRST BAPTIST CHURCH, files this Second
  • Amended Original Petition against Defendant, THE CITY OF CASTLE HILLS, and, in
  • organized and existing under the laws of the state of Texas with its principal place of
  • Antonio, Bexar County, Texas.
  • Texas and is located in Bexar County.
  • The Church is seeking relief under the Texas Uniform Declaratory Judgment Act,
  • a 5 ½-acre parcel of land it owns for a parking lot, or the top floor of its
  • (June 24, 1999 City Council meeting.)
  • Constitutions, the federal Religious Land Use and Institutionalized Persons Act of 2000, 42
  • Plaintiff seeks injunctive, declaratory and compensatory relief under RLUIPA, 42 U.S.C.
  • and favorably act upon the applications submitted by the Church.
  • after granting that church a permit to
  • He was given due process by our committees and our City Council and his request was
  • the whims of the City in order to use its Winston properties for temporary parking.
  • or submitted to either the Zoning Commission or the City Council of the City.
  • "This is not a neighborhood church but a growing mega-church.
  • at which time Anderson distributed the confidential Settlement Agreement and proudly
  • mediated settlement agreement in violation of the spirit of the court's order,
  • Violation of the United States Constitution
  • Paragraphs 1 through 88 are incorporated by reference as if set forth fully herein.
  • Defendant has deprived and continues to deprive Plaintiff of its right to free exercise
  • to the States by the Fourteenth Amendment--by discriminating against Plaintiff because of its
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