Christian Cathedral v. Pan

Background

Christian Cathedral requested a temporary restraining order, an emergency court order, against enforcement of an Alameda County public-health order. The church argued that the order allowed school graduation ceremonies involving up to 25 people, with specified safety protocols, but did not allow religious worship services involving the same number of people and protocols. Christian Cathedral’s constitutional claims relied on that alleged difference in treatment.

Christian Cathedral operates a K–12 school, Patten Academy, and received county guidelines for in-person graduation ceremonies. The guidelines referred to sending an attendee showing COVID-19 symptoms to a separate room and then home. Christian Cathedral inferred that the ceremony could therefore occur indoors. It asked the County whether worship services could be conducted under the graduation guidelines. After receiving no response, the church sent another letter saying it planned to hold a graduation ceremony and worship services in its sanctuary.

Dr. Erica Pan responded that both events were prohibited by the County’s public-health orders because they were indoors. She clarified that the guidelines allowed only outdoor graduation ceremonies.

Court’s Analysis

The court explained that a temporary restraining order is an extraordinary remedy. The requesting party must show a likelihood of success on the merits, likely irreparable harm without emergency relief, that the balance of hardships favors the party, and that an injunction would serve the public interest. Alternatively, the party may show serious questions on the merits, a sharply favorable balance of hardships, and the other required factors.

The court concluded that Christian Cathedral had not met that standard on the current record. The evidence did not adequately support the church’s central factual allegation that Alameda County treated graduation ceremonies more favorably than worship services. Instead, the record showed that the proposed indoor graduation ceremony and worship services were prohibited for the same reason: both were indoors. The court noted that the Constitution permits identical public-health restrictions on worship services and graduation ceremonies. At most, the record showed confusing county guidelines, not a violation of the First or Fourteenth Amendments.

Disposition

The court denied Christian Cathedral’s request for a temporary restraining order. The denial was without prejudice to a later motion for a preliminary injunction based on a more adequate record. Judge Charles R. Breyer entered the order on June 6, 2020.