Monclova Christian Academy v. Toledo-Lucas County. Health Department, No. 20-4300 (6th Cir. 2020)
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The Health Department issued a resolution closing every school in the county—public, private, and parochial—for grades 7-12, effective December 4, to slow the spread of COVID-19. In the same county, gyms, tanning salons, office buildings, and a large casino remained open. Christian schools filed suit, arguing that the closure of their schools amounts to a prohibition of religious exercise in violation of the First Amendment.
The Sixth Circuit, applying strict scrutiny, enjoined enforcement pending appeal, concluding that the closure burdens the plaintiffs' religious practices. The court noted that the schools employed “strict social distancing and hygiene standards” and that “little in-school transmission has been documented.” The court acknowledged that the resolution allowed schools to open for religious education classes or religious ceremonies and that the Department has not targeted the plaintiffs or acted with animus toward religion. The plaintiffs argued that the exercise of their faith is not compartmentalized and pervades each day of in-person schooling so that “a communal in-person environment” is critical to the exercise of their faith. The resolution treats the schools less favorably than it does “comparable secular facilities.” The court rejected an argument that it could consider only the secular actors (other schools) regulated by the resolution. The relevant inquiry is whether the “government, in pursuit of legitimate interests,” has imposed greater burdens on religious conduct than on analogous secular conduct, including gyms, salons, offices, and the Hollywood Casino, which remain open.
The court issued a subsequent related opinion or order on June 21, 2022.
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