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Abstract
As with many high court decisions, what is left unsaid is often as important as what is stated. In Martin v. Corporation of the Presiding Bishop, 747 N.E.2d 131 (Mass. 2001), 53 ZD XX., the Massachusetts Supreme Judicial Court's holding is clear: The Massachusetts Zoning Act and accompanying case law bar unreasonable application of zoning regulations for the use of land or structures for religious purposes.