Westminster-Canterbury of Hampton Roads, Inc. v. City of Virginia Beach

Westminster-Canterbury of Hampton Roads, Inc. (Westminster) is a nonstock, nonprofit corporation which, according to its articles of incorporation, was “organized at the direction of the Commission on Services to the Aging, Episcopal Diocese of Southern Virginia[,] and Tidewater Westminster Homes, Incorporated, of the Norfolk Presbytery of the Presbyterian Church of the United States.” Westminster owns and operates a housing and health-care facility for the elderly in the City of Virginia Beach.

For several years after construction of the facility, Westminster enjoyed a tax-exempt status on…