In Harvest Rock Church v. Newsom, (9th Cir., Jan. 25, 2021), the U.S. 9th Circuit Court of Appeals, relying on the South Bay decision handed down by a different 9th Circuit panel three days earlier (see prior posting) enjoined California from enforcing its COVID-19 related 100- and 200-person limits at places of indoor worship. It however upheld the total ban on indoor worship services in higher risk areas. Judge O'Scannlain concurred specially, criticizing the South Bay decision and arguing that the total ban on indoor worship should also be enjoined. Orange County Register reports on the decision.