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Roberts v. Neace, 958 F.3d 409

Facts

Three congregants of Maryville Baptist Church sought to attend in-person worship services but were prohibited by orders from the Kentucky Governor due to the COVID-19 pandemic. The orders banned all mass gatherings and required non-life-sustaining organizations to close, with religious organizations not classified as life-sustaining unless providing specific services. After attending an Easter service, the congregants were issued notices by state police, leading them to sue the Governor and other officials for violating their rights to free exercise of religion and interstate travel.

Three congregants of Maryville Baptist Church sought to attend in-person worship services but were prohibited by orders from the Kentucky Governor due to the COVID-19 pandemic.

Issue

Did the Governor's orders prohibiting in-person worship services during the COVID-19 pandemic violate the congregants' constitutional rights to free exercise of religion and interstate travel?

Did the Governor's orders prohibiting in-person worship services during the COVID-19 pandemic violate the congregants' constitutional rights to free exercise of religion and interstate travel?

Rule

The court applied the principles of strict scrutiny to evaluate whether the Governor's orders were neutral and generally applicable, determining that laws discriminating against religious practices must be justified by a compelling interest and narrowly tailored to advance that interest.

The court applied the principles of strict scrutiny to evaluate whether the Governor's orders were neutral and generally applicable, determining that laws discriminating against religious practices must be justified by a compelling interest and narrowly tailored to advance that interest.

Analysis

The court found that the Governor's orders likely discriminated against religious practices by allowing numerous secular activities while prohibiting in-person worship services. The court noted that the orders did not treat religious gatherings equally to comparable secular activities, which undermined the neutrality required by the First Amendment. The court emphasized that the congregants were willing to comply with public health guidelines, and the lack of justification for treating religious gatherings differently from secular ones indicated a violation of their rights.

The court found that the Governor's orders likely discriminated against religious practices by allowing numerous secular activities while prohibiting in-person worship services. The court noted that the orders did not treat religious gatherings equally to comparable secular activities, which undermined the neutrality required by the First Amendment.

Conclusion

The Court of Appeals granted the congregants' motion for an injunction pending appeal, enjoining the Governor and other officials from enforcing the orders prohibiting in-person services at the Maryville Baptist Church, provided that the church adheres to public health requirements.

The Court of Appeals granted the congregants' motion for an injunction pending appeal, enjoining the Governor and other officials from enforcing the orders prohibiting in-person services at the Maryville Baptist Church, provided that the church adheres to public health requirements.

Who won?

The congregants prevailed in the case because the court found that their constitutional rights were likely violated by the Governor's orders, which discriminated against religious practices compared to secular activities.

The congregants prevailed in the case because the court found that their constitutional rights were likely violated by the Governor's orders, which discriminated against religious practices compared to secular activities.

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