Nationwide, the growth in renter incomes has outpaced rent growth for the past few years, causing a decrease in the share of cost burdened
The Court first held that closely held, for-profit corporations are "persons" who may bring a claim under RFRA, at least where they are "owned and controlled by members of a single family." (34) Second, the Court held that the regulation at issue substantially burdened
Hobby Lobby's exercise of religion because it forced the company to choose either to violate its religious beliefs or face severe economic consequences.
See ROBINSON, supra note 34, at 145 (defining a burden of persuasion as, "The degree to which the trier of fact must be persuaded in order to decide an issue in favor of the burdened
party.") The burden of production, in contrast, is usually articulated in terms of quantities of evidence: "some evidence" or "more than a scintilla." See ROBINSON, supra note 34, at 136.