Today, the U.S. Supreme Court denied review in Gutay Christian Fellowship v. San Diego County, CA, (Docket No. 11-1451, certiorari denied11/9/2012). (Order List.) In the case, the U.S. 9th Circuit Court of Appeals dismissed on ripeness grounds a church’s RLUIPA land use lawsuit. The church had not actually filed an application for a modification of use permit. (See prior posting.)