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In Tandon v. Newsom, 141 S.Ct. 1294 (2021) (per curiam), the U.S. Supreme Court enjoined pending appeal California s imposition of a blanket limitation during the COVID-19 pandemic on private gatherings of all kinds, religious and secular, in homes to three households. However, California permitted gatherings at other types of locations such as hair salons, retail stores, private suites at sporting events and concerts and indoor restaurants. According to the per curiam, [c]omparability is concerned with the risks various activities pose, not the reasons why people gather ; therefore, these activities are comparable. Government regulations trigger strict scrutiny under the Free Exercise Clause whenever they treat comparable secular activity more favorably than religious exercise. Narrow tailoring requires the government to show that measures less restrictive of the First Amendment activity could not address its interest in reducing the spread of COVID. Moreover, the state cannot

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