2Plaintiff, No Limits Christian Ministries,Inc.,an Idaho church, individually and in itscapacity as representative of certainindividualmembers,bringsthis action for declaratory judgment, temporary restraining order, preliminary and permanent injunction and damagesarising from the Defendants’discriminatory and unequal treatment of its religious assemblyandhereby alleges the following:BACKGROUND AND PARTIES1.Plaintiff, No Limits Christian Ministries (may be referred to hereafter as “NLCM”or the “Church”), is an Idaho churchthat has beenbarred by the City of Mountain Home, Idaho(the “City”)from exercising its rightsto assemble forworship in its leased spaceat 535 N. MainSt., Mountain Home, Idaho 83647 (the “Property”) in violation of its
rights tothe free exercise of religion and freedom of speech and assembly; its
rights to equal protection under the law; its parallel rights under the Religious Land Use andInstitutionalized Persons Act, 42 USC §2000cc, et seq. (“RLUIPA”), the Idaho ReligiousFreedom Act,
Idaho Code § 73-402
,and the IdahoConstitution.2.No Limits Christian Ministries was founded in 2010 when Clark D. Williams, Sr.,an ordained pastorand a licensed Christian counselor,and his wife DanaWilliams beganmeeting with people at theirhome for times of bible study, worship, counseling, and prayer. The purpose of the meetings wasto discover and exalt the hopeandlife found in Jesus and to counselthose seekingmarital, familial, and financial peace.
, Declaration of Pastor Clark D.Williams, Sr. (“Williams Dec.”) ¶¶1-3.3.After only a couple of months,the William’s homecould no longer accommodatethe number of people coming to the meetings, so in March 2010, Pastor Williams begansearching for a temporary location where theycould have an office for counseling and space for
Case 1:11-cv-00255-EJL Document 1 Filed 05/31/11 Page 2 of 36