Must a congregation prove reasonable expectation of zoning approval to establish substantial burden under RLUIPA?

QUESTIONS PRESENTED 1. Must a congregation seeking to build a church prove that it had a reasonable expectation of zoning approval before it can establish that a zoning denial imposed a substantial burden on its religious exercise under RLUIPA, or should substantial burden be established by the totality of the circumstances? 2. Is a congregation precluded as a matter of law from establishing that a zoning denial substantially burdened its religious exercise under RLUIPA if it demonstrates a need for a church with capacity for 2,000 congregants but defendant will only permit an 800-seat church, on the grounds that the zoning denial does not completely prevent it from building a church? 3. To establish an equal terms claim under RLUIPA, must a church identify a secular use given preferential treatment that is identical in all respects to the church’s proposed religious use, or is it sufficient that the secular use and the church’s use implicate the same government regulatory interest? (i)