By the way, RLUIPA gives us a chance to at least familiarize ourselves with how the body of law called "zoning" works.
As the name implies, "zoning" refers to the manner in which local governments control the use of land by enacting a regulation that establishes different restrictions in different zones" of a city or town. (Casebook p. 753). There is a good description of Euclid's zoning ordinance on pages 754-755. As you can see, some zones are single family residential only; others permit duplexes but not apartment buildings; others permit apartment buildings and certain commercial uses; and so on.
This is why you can't build a duplex in a single family residential zone and why you can only operate a commercial establishment in a zone that permits commercial use.
RLUIPA comes into play when a zoning law restricts a religious land use (whether it be a home prayer meeting as in Murphy or a church or religious ministry as in New Life Ministries).
When you read these cases pay attention to how the zoning law restricts land use and how that can cause it to substantially burden or even forbid religious land use.
