Where a U.S. District Court failed to address the central question of whether a city’s zoning code placed undue restrictions on religious uses of a property, remand was required.The 7th U.S. Circuit Court of Appeals reversed a decision by U.S. District Judge Ronald A. Guzman.The city of far south suburban Markham employs a “cumulative” zoning scheme, designating 11 categories of use districts. The various districts are ranked from the highest, most restrictive uses (R-1 one-family residential) to the …