ability to use their property in the exercise of their religion. See Fortress Bible, 694 F.3d at 218 (“[T]o hold that PLUIPA is inapplicable to - what amounts to zoning actions taken in the context of a statutorily mandated environmental quality review would allow towns to insulate zoning decisions from RLUIPA review— [The court] declinefs] to endorse a process that would allow a town to evade RLUIPA by what essentially amounts to a re-characterization of its zoning decisions.”). For example, courts have held zoning ordinances, or zoning decisions, that significantly lessen the prospect of a religious institution’s being able to use the property to further its religious mission contravene RLUIPA. See Guru Nanak Sikh Soc’y of Yuba City v. Cty. of Sutter, 456 F.3d 978, 992 (9th Cir.2006) (<HOLDING>); Roman Catholic Diocese of Rockville Centre v.
holding that laws requiring special use permits did not impose a substantial burden on religious institution holding that the defendant countys two denials of variance permits under the circumstances had to a significantly great extent lessened the prospect of the religious institution being able to construct a temple in the future thus imposing a substantial burden on the religious institutions religious exercise recognizing a religious institutions right to free exercise of religion holding that limitations placed upon the religious activities of two prison groups found to be religious organizations were reasonable under the circumstances holding that religious exercise is any exercise of religion whether or not compelled by or central to a system of religious belief and that the use building or conversion of real property for the purpose of religious exercise shall be considered  religious exercise