CC&Rs challenged under RFRA

[Eugene Volokh]

    Tien Tao Ass'n, Inc. v. Kingsbridge Park Community Ass'n, Inc.,
1997 WL 610085 (Tex. App. Sept. 25) upholds enforcement of covenants,
conditions and restrictions in a deed against a religious
organization that wanted to turn some residential property into a
place of worship.

    The Tex Ct App rejected the RFRA claim on Flores grounds; a
separate Free Exercise Clause claim (and perhaps a Texas state
constitutional claim -- not clear from the decision) was made on
appeal but held to have been waived at trial.

    Query:  What result in, say, D.C. under RFRA?

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