The civil courts often have been called upon to define the term church in the context of zoning laws. There rarely is a question about the status of a building used by a congregation for regular worship services. However, many churches do much more than conduct worship services. Some operate a preschool, elementary or secondary school, homeless shelter, recreational building, camp, bookstore, counseling center, or radio station. Can these kinds of activities be conducted on property that is zoned for "church" use?