In Harvest Rock Church v. Newsom, (CD CA, Sept. 2, 2020), a California federal district court refused to issue a preliminary injunction to a church challenging the state's COVID-19 orders that prohibit indoor church services. The court said in part:
Because the Orders restrict indoor religious services similarly to or less than comparable secular activities, it is subject to rational basis review, which it easily passes: by limiting certain activities, the Orders reduce person-to-person contact, which in turn furthers the interest of reducing COVID-19 spread. Accordingly, Plaintiffs are not likely to succeed on the merits of their Free Exercise Claim.