On Nov. 25, 2020, the Supreme Court decided Roman Catholic Diocese of Brooklyn v. Andrew Cuomo [1] in a 5-4 ruling. That decision struck down Gov. Cuomo's executive order limiting to ten the number of individuals who could gather in places of worship in hard-hit “red zones.” As COVID's US toll continues to increase and vaccination efforts fumble, we can expect frustrated governors and public health officials to seek to enforce a broader panoply of lockdown orders. The Diocese case teaches a few lessons to assure new orders don’t trespass on the new-found Religious devotion of the Supreme Court.
