We previously reported on a lawsuit filed by the Beloved Church in Lena, Illinois to challenge Governor Pritzker’s executive order that previously restricted places of worship to 10 in-person attendees. The district court had denied injunctive relief, finding that the Governor’s executive order furthered the government’s interest in protecting people from the pandemic and there were alternative methods for worship. The Church appealed to the Seventh Circuit Court of Appeals which issued an opinion recently affirming the district court but on different grounds. Cassell and Beloved Church v. Snyders.

The Court of Appeals noted that much had changed since the district court’s May ruling denying the injunctive relief requested by the Beloved Church. First, the Governor’s executive order that restricted places of worship to ten worshipers is no longer in place, having been replaced with a recommendation (rather than a mandated restriction) to limit worshipers. Also, the U.S. Supreme Court had since issued a number of rulings on COVID-related restrictions on religious institutions, some of which had found similar restrictions to be unconstitutional. The Seventh Circuit recognized these Supreme Court precedents but did not grant the Beloved Church its requested injunction against the Governor’s restrictions finding that there was little risk that the Church would suffer any irreparable injury since the mandatory restrictions had previously been abandoned by the Governor and there was a very low likelihood that they would be reinstated given the availability of vaccines and the ongoing reduction in COVID cases.