RLUIPA not unconstitutional under the Tenth Amendment

On remand in Cutter v. Wilkinson, the Sixth Circuit held that the institutionalized persons aspect of the Religious Land Use and Institutionalized Person Act is not an unconstitutional exercise of the Spending Clause power of Congress, where the state claims that it was in violation of the Tenth Amendment.

It's hard to imagine cases where the Tenth Amendment has some substantive application - although I wonder if there are some Tenth Amendment issues lurking in connection with the Hurricane Katrina relief effort.