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Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

plaintiffinjunctionappealmotionregulation
plaintiffappealregulationdue process

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Tandon v. Newsom, 593 U.S. 61, 141 S.Ct. 1294, 209 L.Ed.2d 355, 21 Cal. Daily Op. Serv. 3194, 2021 Daily Journal D.A.R. 3359, 28 Fla. L. Weekly Fed. S 741

Facts

Plaintiffs sought to gather for at-home religious exercise but were restricted by the State's Blueprint System during the COVID-19 pandemic. They alleged that these restrictions violated their First Amendment rights, including free exercise, free speech, and freedom of assembly, as well as their Fourteenth Amendment rights. The United States District Court for the Northern District of California denied their motion for a preliminary injunction, prompting an appeal. The Ninth Circuit also denied their motion for emergency injunctive relief pending appeal.

Plaintiffs, who wished to gather for at-home religious exercise, brought action alleging that State's Blueprint System for restrictions on private gatherings during COVID-19 pandemic violated their First Amendment rights to free exercise, free speech, and freedom of assembly and their Fourteenth Amendment substantive due process and equal protection rights.

Issue

Whether the State's restrictions on private gatherings during the COVID-19 pandemic violated the plaintiffs' rights under the Free Exercise Clause of the First Amendment.

Whether secular and religious activities are comparable for purposes of the Free Exercise Clause, so that strict scrutiny is triggered if the government treats a comparable secular activity more favorably than religious exercise, must be judged against the asserted government interest that justifies the regulation at issue.

Rule

Government regulations that are not neutral and generally applicable trigger strict scrutiny under the Free Exercise Clause when they treat comparable secular activities more favorably than religious exercise. The government must demonstrate that its restrictions are narrowly tailored to serve a compelling interest, and it cannot assume that religious gatherings are inherently more dangerous than comparable secular activities.

Government regulations are not neutral and generally applicable, and therefore trigger strict scrutiny for a violation of the Free Exercise Clause, whenever they treat any comparable secular activity more favorably than religious exercise.

Analysis

The court found that the State's restrictions included numerous exceptions for secular activities, which triggered strict scrutiny. The State failed to adequately justify why it could not allow at-home worshipers to gather in larger numbers while using the same precautions as secular activities. The court emphasized that the government must show that religious gatherings pose a greater risk than those secular activities that are permitted.

For the government to meet its burden of establishing that its restrictions on gatherings during the COVID-19 pandemic satisfy strict scrutiny for a violation of the Free Exercise Clause, the government must do more than assert that certain risk factors are always present in worship, or always absent from the other secular activities the government may allow.

Conclusion

The Supreme Court granted the plaintiffs' application for emergency injunctive relief pending appeal, indicating that they were likely to succeed on the merits of their free exercise claim.

Plaintiffs, who wished to gather for at-home religious exercise, were entitled to emergency injunctive relief pending appeal, in their action challenging under the Free Exercise Clause a State's restrictions on private gatherings during COVID-19 pandemic.

Who won?

The plaintiffs prevailed in their application for emergency injunctive relief. The Supreme Court determined that the State's restrictions on at-home religious gatherings were not justified, as they treated comparable secular activities more favorably. The Court emphasized that the State had not demonstrated that allowing larger gatherings for religious purposes would pose a greater risk than those secular activities that were permitted, thus affirming the plaintiffs' rights under the Free Exercise Clause.

The Supreme Court held that plaintiffs were likely to succeed on the merits of their free exercise claim; they were irreparably harmed by the loss of free exercise rights for even minimal periods of time, and the State had not shown that public health would be imperiled by employing less restrictive measures.

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