Seventh Circuit Upholds Denial of Preliminary Injunction in Religious Gathering Restrictions Amid Pandemic

Introduction

In the case of Stephen Cassell and The Beloved Church v. David Snyders, et al., the United States Court of Appeals for the Seventh Circuit affirmed the district court's denial of a preliminary injunction that sought to lift a ten-person limit on religious gatherings imposed by Illinois authorities to mitigate the spread of COVID-19. The plaintiffs, a Christian church and its pastor, argued that the restrictions infringed upon their First Amendment rights and violated due process under the Fourteenth Amendment.

Summary of the Judgment

The Seventh Circuit upheld the district court's decision to deny the preliminary injunction petition filed by The Beloved Church and Pastor Stephen Cassell. The plaintiffs contended that the ten-person limit on religious gatherings was unconstitutional. However, the court found that:

• The likelihood of the plaintiffs succeeding on the merits of their First Amendment and state-law claims was low.
• The threat of irreparable harm was minimal, especially given the lapse of the ten-person limit and subsequent executive orders exempting religious gatherings.
• Public interest favored the denial of the injunction to protect public health during the pandemic.

Consequently, the appellate court affirmed the denial, emphasizing the need for courts to exercise restraint in granting temporary injunctions during public health emergencies.

Analysis

Precedents Cited

The judgment extensively referenced key Supreme Court decisions that shaped the legal landscape for religious freedom and preliminary injunctions during emergencies:

• Roman Catholic Diocese of Brooklyn v. Cuomo: Affirmed that restrictions on religious gatherings must pass strict scrutiny, ensuring they are narrowly tailored to serve a compelling governmental interest.
• Danville Christian Academy, Inc. v. Beshear: Highlighted that equitable considerations often weigh against granting preliminary injunctions when the threat of irreparable harm is low.
• ELROD v. BURNS: Established that any loss of First Amendment freedoms constitutes irreparable injury.
• GRISWOLD v. CONNECTICUT and LAWRENCE v. TEXAS: Emphasized the fundamental right to individual liberty and privacy.

Legal Reasoning

The court applied the standard for preliminary injunctions, which involves:

1. Assessing the likelihood of success on the merits.
2. Determining the absence of adequate legal remedies and the presence of irreparable harm.
3. Balancing the irreparable harm to the plaintiffs against the harm to the non-moving parties and public interest.

In this case, the plaintiffs failed to demonstrate a strong likelihood of success, especially after the ten-person limit was lifted and subsequent executive orders exempted religious gatherings. Additionally, the potential public health risks associated with religious gatherings during a pandemic outweighed the plaintiffs' interests.

Impact

This judgment reinforces the strict scrutiny applied to restrictions on religious freedoms, especially during public health crises. It underscores the judiciary's deference to state and local authorities in balancing public health and constitutional rights. Future cases involving similar restrictions will likely reference this ruling, setting a precedent for the high bar plaintiffs must meet to obtain preliminary injunctions against public health measures.

Complex Concepts Simplified

Preliminary Injunction

A preliminary injunction is a temporary court order that halts a party's actions until the court can make a final decision. To obtain it, the applicant must show:

• **Likelihood of Success:** The applicant is likely to win the case.
• **Irreparable Harm:** The applicant will suffer harm that cannot be undone if the injunction is not granted.

Additionally, the court considers the balance of harms and public interest before deciding.

Eleventh Amendment Immunity

The Eleventh Amendment provides states and their officials with sovereign immunity, protecting them from certain lawsuits in federal courts. In this case, it potentially shields state and local officials from being sued for enforcing the ten-person limit on religious gatherings.

Strict Scrutiny

Strict scrutiny is the highest standard of judicial review. Laws or policies subjected to strict scrutiny must serve a compelling governmental interest and must be narrowly tailored to achieve that interest without unnecessary restrictions.

Conclusion

The Seventh Circuit's affirmation in Cassell v. Snyders underscores the judiciary's cautious approach to intervening in state-imposed public health measures that restrict religious freedoms. By denying the preliminary injunction, the court recognized the necessity of balancing constitutional rights with public health imperatives during unprecedented times like a pandemic. This decision serves as a pivotal reference point for future litigation involving similar conflicts between religious exercise and state-enforced health regulations.

Ultimately, the judgment highlights the importance of demonstrating both a strong likelihood of success on constitutional grounds and the presence of irreparable harm to overcome the high threshold required for preliminary injunctions in sensitive contexts.