Iowaska Church of Healing v. Rettig

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA IOWASKA CHURCH OF HEALING, Plaintiff, Civil Action No. 21-02475 (BAH) v. Judge Beryl A. Howell UNITED STATES OF AMERICA, et al., Defendants. MEMORANDUM OPINION Plaintiff Iowaska Church of Healing is a non-profit organization whose members’ sincerely-held religious belief partly involves the consumption of the Sacrament of Ayahuasca (“Ayahuasca”), a tea brewed from South American plants that contains a drug illegal under federal law. Pl.’s SMF ¶¶ 5-6, 14-15, ECF No. 20-1. On January 10, 2019, plaintiff filed Form 1023 with the Internal Revenue Service (“IRS”), requesting recognition as a tax-exempt organization, pursuant to 26 U.S.C. § 501(c)(3) of the Internal Revenue Code of 1986, and as a church within the meaning of 26 U.S.C. § 170(b)(1)(A)(i). Id. ¶ 35. The IRS denied that application, both because plaintiff was not organized and did not operate exclusively for exempt purposes and because using Ayahuasca is illegal under federal law and violates public policy. AR, Ex. 18 at 1 (“IRS Determination Letter”). 1 Plaintiff sued the IRS’s administrator, in his official capacity, and the federal government, claiming, first, that the IRS erred in its analyses of application of both § 501(c)(3) and 1 The Administrative Record (“AR”) in this case is voluminous and, in accordance with the local rules, the parties filed a Joint Appendix, containing portions of the AR cited or otherwise relied upon for the pending motions. See D.D.C. LCvR 7(n); Joint App’x at 1, ECF No. 29. The 303-page Joint Appendix is docketed in eighteen separate attachments, see ECF Nos. 29-1–18. For clarity, “AR” citations herein are to those documents from the administrative record found in the Joint Appendix. 1 § 170(b)(1)(A)(i), and, second, that the IRS’s decision violated plaintiff’s rights under the Religious Freedom Restoration Act (“RFRA”), 42 U.S.C. § 2000bb et seq. See generally Am. Compl., ECF No. 16. The parties have now filed cross-motions for summary judgment on both claims. See Pl.’s Mot. for Summ. J. (“Pl.’s Mot.”), ECF No. 20; Pl.’s Mem. Supp. Mot. for Summ. J. (“Pl.’s Mem.”), ECF No. 20-3; Def.’s Opp’n to Pl.’s Mot. for Summ. J. & Cross-Mot. for Summ. J. (“Defs.’ Cross-Mot.”), ECF No. 23; see also Def.’s Mem. Supp. Opp’n to Pl.’s Mot. for Summ. J. & Cross-Mot. for Summ. J. (“Defs.’ Mem.”), ECF No. 23-1. For the reasons below, defendants’ cross-motion is granted, and plaintiff’s motion is denied. I. BACKGROUND The relevant factual and procedural background is described below. A. Factual Background The material facts are not disputed. Plaintiff was incorporated, in Iowa, as a nonprofit religious corporation, on September 24, 2018, under Iowa Code § 504.141(38). AR, Ex. 4 at 19. Since March 19, 2019, plaintiff has also been registered to do business in Florida. Pl.’s SMF ¶ 1. Plaintiff’s self-described mission is “to offer the public access to spiritual growth, development and healing through the sacred Sacrament of Ayahuasca,” id. ¶ 5, which is a tea brewed from plants native to South America that contain dimethyltryptamine (“DMT”), id. …

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