In Gibson v. City of Vancouver, 2020 U.S. Dist. LEXIS 232408 (WD WA, Dec. 3, 2020), a Washington federal district court refused to issue a temporary restraining order to protect a street preacher who planned to hold a 20-person outdoor prayer protest at a public park to oppose the governor's COVID-19 orders. The court held that plaintiff lacks standing to sue, saying in part that plaintiff:
has not demonstrated that any of the Defendants he sued have communicated a specific warning or threat to initiate any proceedings against him if he carries out his plan...
