Sacrament Collective Pentecostal Church, Inc v. County of Santa Cruz

Background

Sacrament Collective Pentecostal Church, Inc. is a nonprofit religious corporation with a branch in San Jose. Its central religious belief involves the sacramental use of cannabis. The complaint alleged that the church stored cannabis, donations, and other items at 191 Station Ranch Road in Scotts Valley, a residence owned by Davide Berti and used by Berti and Corinna Reyes.

The defendants were the County of Santa Cruz, the Santa Cruz County Sheriff’s Office, and the Santa Cruz County Human Services Department. The events began with a welfare-fraud investigation involving Reyes and Berti. During that investigation, county personnel learned of connections to cannabis businesses and confirmed that neither Reyes nor Berti was authorized to operate a cannabis business in the county.

Officials obtained and served a search warrant at the residence on March 14, 2019. They arrested church members and seized cannabis and currency. The search uncovered an indoor marijuana cultivation site with more than 100 plants, approximately 90 pounds of processed marijuana, approximately 10 pounds of concentrated cannabis, more than 1,000 vape-pen cartridges, and more than $155,000 in cash. The seizure led to criminal charges and convictions for Reyes and Berti.

The church filed this action in state court, and the defendants removed it to federal court. The case was later stayed while related criminal proceedings were resolved. The church did not attend two later case-management conferences, did not respond to an order to show cause concerning its counsel’s failure to appear, and did not oppose the defendants’ summary-judgment motion.

Claims and Legal Standards

The complaint asserted claims under 42 U.S.C. § 1983 for alleged First Amendment violations, the Religious Land Use and Institutionalized Persons Act (RLUIPA), and California Civil Code section 52.1, known as the Bane Act. The complaint’s requests for declaratory and injunctive relief were remedies rather than separate causes of action.

Summary judgment is appropriate when the evidence shows no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment under the law. The court could not grant the unopposed motion merely because the church filed no opposition; it had to determine whether the defendants’ evidence supported judgment and revealed no genuine factual dispute.

Analysis

Section 1983 claim. The church appeared to allege that the defendants violated the First Amendment by burdening religious exercise, seizing property, and detaining members. The court applied the Heck preclusion doctrine, which generally bars a damages claim under § 1983 when winning the claim would necessarily imply that an existing criminal conviction is invalid, unless that conviction has already been overturned or otherwise invalidated.

The court found that success on the church’s claim would necessarily imply the invalidity of Reyes’s and Berti’s convictions. Their pleas and convictions arose from the same conduct underlying the church’s claims: the seizure of marijuana at the residence and their detention on criminal charges. The court therefore held that the convictions precluded the church’s § 1983 claim under Heck. The court also stated that the church was independently barred from relitigating the issue under principles of collateral estoppel.

The court separately addressed the substance of the church’s First Amendment claim. It explained that religious belief is protected, but religiously motivated conduct remains subject to neutral laws of general applicability. The court concluded that the defendants enforced neutral state laws and generally applicable codes prohibiting unregistered large-scale cannabis activity. It found that the evidence did not show the defendants had prevented the church or its members from using or possessing cannabis in lawful quantities as a sacrament. The court therefore ruled that the defendants’ actions did not violate the First Amendment’s protection of religious exercise.

RLUIPA claim. The court interpreted the church’s RLUIPA allegations as asserting an “equal terms” claim rather than a substantial-burden claim. An equal-terms claim concerns whether a government imposes or enforces a land-use regulation against a religious assembly on less equal terms than against a nonreligious assembly or institution.

The court found that the first three elements were undisputed: there was a land-use regulation, it was imposed by a government body, and it applied to the church as a religious institution. But the church produced no evidence that it was treated less favorably than a similarly situated organization. The uncontested evidence showed that organizations engaged in commercial cannabis activity had to comply with county and state registration and licensing requirements, and the church had not registered with the county or obtained state licensure. The court granted summary judgment on the RLUIPA claim because the church failed to create a factual dispute about unequal treatment.

Bane Act claim. The Bane Act permits a claim when threats, intimidation, or coercion interfere with a right protected by federal or state law. The court explained that a Bane Act claim cannot succeed without an underlying constitutional or statutory violation. Because the church’s First Amendment and RLUIPA claims failed, those claims could not support the Bane Act claim. The court also rejected the church’s related claim under the California Constitution’s religious-freedom provision, finding no evidence that the challenged enforcement improperly infringed religious liberty.

The court noted that the regulations limited the church’s commercial cannabis activity while permitting members’ sacramental use of cannabis. It found that the defendants seized the cannabis while enforcing facially neutral laws in a nondiscriminatory manner during an investigation of unlicensed commercial cannabis activity and welfare fraud. The court therefore found no material factual dispute supporting the Bane Act claim.

Disposition

The court granted defendants’ motion for summary judgment. The ruling disposed of the entire case, and the clerk was directed to close the file.