Introduction
In April 2019, shortly after Covid-19 began, Nevada Governor Brian Sandoval signed an executive order requiring all businesses with more than 50 employees to submit letters of approval from their clergy. This was before they could hold any public events or activities. The order also required companies that had previously held such events or activities to submit new letters every six months until their next meeting with government officials. The Supreme Court of the United States denied an emergency application by the Calvary Chapel to hold religious services in Nevada. The case began when the State of Nevada enacted Covid-19, which ordered all citizens to remain in their homes and not leave them unless they traveled to attend emergencies. This order was later amended to include any religious gathering that does not involve food or water. Calvary Chapel filed an emergency application for relief with the Supreme Court of Nevada, asking for an immediate review of this law. The Supreme Court denied their request, explaining that it could not rule on an emergency application within its jurisdiction because it required a three-judge panel to hear the case and decide its merits.
Case Outline
Case Title
Calvary Chapel Dayton Valley v. Steve Sisolak
Facts of the Case
In its complaint, the Church claimed that Covid-19 had created a discriminatory atmosphere for religious groups in Nevada. Specifically, it argued that Covid-19 violates both the Free Exercise Clause and Equal Protection Clause because it targets religious organizations unfairly by singling them out for unfavorable treatment while allowing gambling establishments to operate without restriction.
History of the Case
The Calvary Chapel claims that a state directive allowing non-essential businesses, such as casinos and water parks, to operate at 50% capacity (Calvary Chapel Dayton Valley v. Steve Sisolak,2021). However it prohibit places of worship from congregating with more than 50 people under any circumstance is discriminatory and violates their right to Free Exercise, Free Speech and Public Assembly.
Legal Questions
- Does the State have a compelling interest in protecting public health and safety during times of crisis?
- Is there any other way to achieve this goal without violating religious freedoms?
Decision or Holdings
The Court ruled that there was no violation of the Church’s rights under either the Free Exercise Clause or the Free Speech Clause of the First Amendment. This was because it was not clear that these clauses were intended to protect religious organizations from laws that are neutral on their face (Buckner, 2021). This means that the court does not believe these clauses would protect churches from non-discriminatory laws aimed at keeping public spaces free from religious messages. However, this does not mean that these clauses cannot be used to challenge laws like Covid-19 in future cases; it only means that Covid-19 is not at risk of being overturned by this decision.
Verdict and Opinion
The court found that Covid-19 did not violate the First Amendment because it does not burden religious speech or conduct. Instead, it merely regulates how these organizations can operate within their physical confines when those spaces are reserved for religious purposes only (i.e., chapels). The court found that the State’s purpose in enacting Covid-19 was not aimed at disfavoring religion but rather at protecting public health and safety. The court also held that while there may be some tension between protecting public health and safety and protecting religious freedom, this conflict was not so great as to justify overturning Covid-19.
Conclusion
The court’s decision was based on a balancing test that weighed the government’s interests in public safety against religious rights. The citizen benefitted since the number of COVID cases reduced thus this was a good decision. The court ruled that “the State’s compelling interest in protecting its citizens from violent crime justified a complete ban on assembly.
References
Buckner, L. (2021). How favored, exactly? An Analysis of the most favored nation theory of religious exemptions from Calvary Chapel to Tandon. Notre Dame Law Review, 97, 1643. Web.
Calvary Chapel Dayton Valley v. Steve Sisolak, 141 S. Ct. 1285 (U.S. 2021).