Bishop McDonnell Explains. 2.

"Pastoral planning is an integral religious responsibility of the Diocese guided by its core religious obligation to spread the gospel message of Jesus Christ and provide for the sacramental needs of its members." (paper 13.1., page 8)

"By this ordinance the City purports to exercise near total governmental control over the RCB's religious symbols, an integral part of the exterior of this church, thereby frustrating the Bishop's exercise of his obligations under Church doctrine, scripture and Canon Law to take measures to move, reuse, relocate, remove, destroy or obscure them in order to prevent desecration . . . . The Ordinance substantially impedes the Bishop's ability to carry out his religious duties." (13.1, p. 10)

". . . the RCB's religious symbols on the exterior of OLOH Church also enjoy protection as free speech.. . . OLOH Church itself was purposely constructed and maintained in the shape of the Christian Cross seen as a representation of the instrument of the crucifixion of Jesus Christ, and is the best-known religious symbol of Christianity. . . . The exterior religious architectural details of OLOH Church are expressions and reflections by the RCB of the Roman Catholic faith and are explicitly and deliberately designed to communicate and identify the structure to all as a Roman Catholic church, to praise God and to exhort those who see it, whether Roman Catholic or not, to reflect upon Jesus Christ and the Word and glory of God. . . . " (13.1, p. 14-15)

". . . Placing these exterior religious symbols, all rooted in sacred scriptures, under government control through the creation of the OLOH Historic District essentially freezes in place these religious symbols...so that the Bishop is substantially impeded in the exercise of his responsibilities under Church doctrine, scripture and Canon Law either to remove or relocate them (as part of a sale to a third party), or to otherwise prevent their desecration or other sordid use...
...the religious symbols appearing on the exterior of the OLOH Church constitute "ecclesiastical goods" ...and are subject to the oversight of Rome and the Bishops. These religious symbols are part of the patrimony of the Diocese of Springfield. The Roman Pontiff is the supreme administrator of all ecclesiastical goods...
...In Smith, the Supreme Court emphasized that, when applying the "substantial burdens" text, courts must avoid "judging the centrality of different religious practices [because it] is akin to the unacceptable business of evaluating the relative merits of differing religious claims."...
..."It is not within the judicial ken to question the centrality of particular beliefs of practices to a faith, or the validly of particular litigant's interpretations of those creeds." (Hernandez v Comm'r).
[The] Supreme Court precedent identifies the existence of such a burden when government puts substantial pressure on an adherent to modify his behavior and to violate his beliefs (Thomas v. Review Bd. of Indiana)...
...The City cannot seriously contend that its creation of the OLOH Historic District capturing control of [these sacred symbols] does not substantially burden the RCB in its free exercise of religion." (13.1. p. 17-18)