In Gateway City Church v. Newsom, (ND CA, Jan. 29, 2021), a California federal district court, discussing recent 9th Circuit and Supreme Court precedents, upheld portions of COVID-19 state and county restrictions on worship services, while preliminarily enjoining other parts of the state's orders. The court upheld the state prohibition on indoor worship in Tier I high risk areas. It also upheld the county's general prohibition on gatherings of all sorts. The court however enjoined enforcement of state 100- and 200- person capacity limits in Tier II and III recovery-- but allowed percentage-based capacity limits. Finally it enjoined restrictions on activities other than worship services in houses of worship.
