In Elim Romanian Pentecostal Church v. Pritzker, (7th Cir., Jan. 11, 2022), the U.S. 7th Circuit Court of Appeals affirmed an Illinois federal district court's denial of an injunction against a now-rescinded COVID order by the Governor of Illinois limiting the number of people who could attend a religious service. The district court based its decision on mootness grounds, even though the 7th Circuit had previously held the case was not moot. The 7th Circuit now said however:
More than 19 months have passed since they were last subject to an attendance limit, and the Governor has not suggested that another is likely. A legal conclusion that a rescinded order violated the Constitution would not entitle anyone to an injunction....
