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 ...