Introduction

The case of Monclova Christian Academy; St. John's Jesuit High School & Academy; Emmanuel Christian School; Citizens for Community Values dba Ohio Christian Education Network v. Toledo-Lucas County Health Department addresses the tension between public health measures and religious freedoms during the COVID-19 pandemic. Plaintiffs, comprising nine Christian educational institutions, challenged a county resolution mandating the closure of all schools for grades 7-12 to mitigate the spread of COVID-19. They contended that this closure disproportionately targeted their religious schools, thereby infringing upon their First Amendment rights to freely exercise religion.

Summary of the Judgment

The United States Court of Appeals for the Sixth Circuit, in a decision dated December 31, 2020, granted the plaintiffs' motion for a preliminary injunction pending appeal. The court determined that the Toledo-Lucas County Health Department's resolution was not a neutral law of general applicability as required by the First Amendment's Free Exercise Clause. Specifically, the court found that while the resolution mandated the closure of religious schools, other comparable secular establishments like gyms and casinos remained open, thereby imposing greater burdens on religious exercise. Consequently, the plaintiffs' right to freely exercise their religion was infringed, warranting the injunction against the enforcement of the closure order on their institutions during the appeal process.

Analysis

Precedents Cited

The judgment extensively references pivotal Supreme Court cases that shape the interpretation of the Free Exercise Clause:

• Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah (1993): Established that laws burdening religious practices must be neutral and of general applicability, failing which they are subject to strict scrutiny.
• Burwell v. Hobby Lobby Stores, Inc. (2014): Highlighted that religious corporations are protected under the Free Exercise Clause.
• Employment Division v. Smith (1990): Articulated that neutral laws of general applicability do not violate the Free Exercise Clause, even if they incidentally burden religious practices.
• Roman Catholic Diocese of Brooklyn v. Cuomo (2020): Emphasized that the Free Exercise Clause prohibits the government from treating religious activities less favorably than comparable secular activities.
• Kentucky ex. rel. Danville Christian Academy, Inc. v. Beshear (2020): Dealt with similar COVID-19 related school closures, distinguishing the treatment of religious and secular schools.

Legal Reasoning

The court's legal reasoning hinged on whether the health department's resolution was a "neutral law of general applicability." The plaintiffs argued that the closure disproportionately affected religious schools compared to secular establishments, thereby burdening their free exercise of religion. The court agreed, noting that the resolution was not applied uniformly across comparable secular entities, which continued operations despite similar or greater health risks. This inconsistent application indicated a lack of general applicability and suggested that the resolution targeted religious institutions, necessitating strict scrutiny under the Free Exercise Clause.

Additionally, the court rejected the health department's argument that the closure did not burden religious practices, pointing out that the plaintiffs integrated their faith into daily school operations, making in-person attendance essential to their religious expression. This interconnectedness further supported the plaintiffs' claim that the resolution impeded their free exercise rights.

Impact

This judgment sets a significant precedent for how public health measures intersect with religious freedoms. By applying strict scrutiny to the closure of religious schools while allowing comparable secular institutions to remain open, the court reinforces the necessity for laws affecting religious practices to be applied uniformly and without discrimination. Future cases involving restrictions on religious activities may reference this decision to argue against disproportionate burdens on religious institutions.

Moreover, the decision underscores the importance of considering the broader context of governmental restrictions, rather than evaluating them in isolation. This holistic approach ensures that all aspects of the law are examined to prevent subtle forms of discrimination against religious practices.

Complex Concepts Simplified

Free Exercise Clause: A provision in the First Amendment that protects individuals' rights to practice their religion without government interference.

Neutral Law of General Applicability: Laws that apply equally to all individuals, regardless of their religious beliefs or practices, and do not target any specific religious activity.

Strict Scrutiny: The highest standard of judicial review. To pass strict scrutiny, a law must serve a compelling government interest and must be narrowly tailored to achieve that interest.

Preliminary Injunction: A court order made in the early stages of a lawsuit which prohibits the parties from taking certain actions until the court has decided the case.

Amicus Curiae: Latin for "friend of the court." Refers to someone who is not a party to a case but offers information or expertise relevant to the case.

Conclusion

The Sixth Circuit's decision in this case underscores the paramount importance of safeguarding religious freedoms, especially in times of widespread governmental interventions like the COVID-19 pandemic. By determining that the health department's resolution was not of general applicability and disproportionately impacted religious schools, the court reaffirmed that laws affecting religious practices must be applied uniformly and without favoritism. This judgment not only serves as a crucial safeguard for religious institutions but also provides a clear framework for evaluating the constitutionality of future restrictions that may impinge upon the free exercise of religion. It emphasizes the judiciary's role in ensuring that public health measures do not inadvertently or deliberately undermine fundamental religious rights.