I.INTRODUCTION
II.STATEMENT OF RELEVANT FACTS
III.SUMMARY OF APPLICABLE LAW 
A.Standard for Motion to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(1)
B. Standard for Fed. R. Civ. P. 12(c) Judgment on the Pleadings Based on a Fed. R. Civ. P. 12(b)(6) Failure to State a Claim on Which Relief Can Be Granted
C.Brief Background on Connecticut Land Use Law
D.Background on the Religious Land Use and Institutionalized Persons Act
IV.ARGUMENT
A.This Court Lacks Subject Matter Jurisdiction Because This Case Is Not Ripe 
1.Plaintiff has not satisfied the constitutional requirements for ripeness
a. Plaintiff has not begun to exhaust the available local and state procedures
b.Plaintiff has not satisfied the finality requirement
c.Exhaustion and Finality Must Be Strictly Enforced in Land Use Cases Due to the Constitution’s Inherent limits of Federalism and the Tenth Amendment.
2.Plaintiff Has Not Satisfied the Prudential Requirements for Ripeness 
a.The plaintiff will suffer no hardship in the absence of review
b. The issues are not fit for federal judicial review as a prudential matter
B.RLUIPA IS UNCONSTITUTIONAL
1.RLUIPA Violates Principles of Federalism and the Tenth Amendment