Case: Elim Romanian Pentecostal Church v. Pritzker

1:20-cv-02782 | U.S. District Court for the Northern District of Illinois

Filed Date: May 7, 2020

Case Ongoing

Clearinghouse coding complete

Case Summary

COVID-19 Summary: On May 7, two churches in Illinois sued the Governor of Illinois, seeking declaratory and injunctive relief against the Governor’s stay-at-home order and restoration plan, which limited gatherings to 10 or fewer people. The court denied the request for a TRO on May 13, the Seventh Circuit denied the plaintiff's request for an injunction pending appeal, and the Supreme Court denied the appeal on May 27. On June 16, the Seventh Circuit affirmed. The plaintiffs sought en banc reh…

COVID-19 Summary: On May 7, two churches in Illinois sued the Governor of Illinois, seeking declaratory and injunctive relief against the Governor’s stay-at-home order and restoration plan, which limited gatherings to 10 or fewer people. The court denied the request for a TRO on May 13, the Seventh Circuit denied the plaintiff's request for an injunction pending appeal, and the Supreme Court denied the appeal on May 27. On June 16, the Seventh Circuit affirmed. The plaintiffs sought en banc rehearing, which was denied by the Seventh Circuit; a writ of certiorari was also denied by the Supreme Court on March 26, 2021. The district court granted a motion to dismiss on July 26, 2021 and the plaintiffs immediately appealed.


On May 7, the Elim Romanian Pentecostal Church and Logos Baptist Ministries filed this action against Governor J.B. Pritzker, seeking to overturn the restrictions on religious activities imposed by the stay-at-home order and his “Restore Illinois” plan. The plaintiffs brought this case in the U.S. District Court for the Northern District of Illinois as a declaratory action under 28 U.S.C. §§ 2201-02, and as an injunctive action under 42 U.S.C. § 1983, the Religious Land Use and Institutionalized Persons Act, and state law. Specifically, the two Chicago-area churches argued that the plan, which continues to limit in-person gatherings to 10 or fewer people for the first 3 phases and threatens criminal sanctions for noncompliance, was unconstitutional. The case was assigned to Judge Robert W. Gettleman and Magistrate Judge Judge Jeffrey I. Cummings.

On May 8, the plaintiffs sought a temporary restraining order (TRO) to prevent the government from enforcing the gathering orders, which would keep the plaintiffs and their congregants from being subject to criminal sanctions for hosting in-person worship services where they were implementing social distancing and hygiene protections.

On May 13, the district court denied the request for TRO and preliminary order, finding that “[t]he Order, without doubt, is rationally based in light of the need to slow the spread of COVID-19 in Illinois.” Judge Gettleman, pointing out that none of the those participating in the religious activity were wearing protective masks, claimed that the plaintiffs’ request and “blatant refusal to follow the mandates of the Order are both ill-founded and selfish.” 2020 WL 2468194. The plaintiffs appealed to the Seventh Circuit the next day requesting an injunction pending appeal, which was denied on May 16. 2020 WL 2517093. On May 27, the plaintiffs appealed to the U.S. Supreme Court.

On May 29, the Governor issued Executive Order 38, which superseded the Executive Order at issue. The new order removed the limitations on religious gatherings and specifically exempted the free exercise of religion from the restrictions outlined in the order. The defendants moved to dismiss the appeal the same day, claiming that the case has become moot as the restrictions underlying plaintiffs’ request for preliminary injunctive relief were no longer in effect. The same day, the U.S. Supreme Court denied the application for injunctive relief, citing a new public health guideline issued on May 28 by the Illinois Department of Health. 2020 WL 2781671.

On June 2, the defendant moved to stay pending appeal. The plaintiffs did not oppose the motion, and the court granted the stay on June 8.

On June 16, the Seventh Circuit affirmed the district court's denial of the injunction, finding that religious services were analogous to congregate functions that occur in auditoriums, such as concerts and movies. Such indoor activities put "members of multiple families close to one another for extended periods, while invisible droplets containing the virus may linger in the air." They stated that unlike some necessary activities, like meatpacking warehouses or care for the elderly, religious gatherings could alternatively happen through the internet, small worship gatherings, or drive-in services. Ultimately, they held that the new Executive Order had not discriminated against religion, and thus had not violated the First Amendment. 962 F.3d 341

The plaintiffs requested a rehearing en banc on July 10, which was denied by the entire Seventh Circuit panel on July 27. On September 3, the defendants requested a stay pending appeal, which the court granted; the stay was later extended until April 15, 2021. The plaintiffs filed writ of certiorari to the United States Supreme Court on October 22, 2020, which was denied on March 26, 2021.

On May 14, 2021 the defendant filed a motion to dismiss, arguing that the claims for injunctive relief were now moot, due to the executive order expiring in May 2020. Judge Gettleman agreed and dismissed the claims as moot on July 26, 2021, stating that there was no order in place and no credible threat of reinstatement warranting further protection of the court. The court also dismissed the plaintiffs' claims for damages, stating that they had waived their objections by not responding to the defendant's claims of sovereign and qualified immunity barring damages. The plaintiffs appealed the order the same day and the appeal remains ongoing. (Case No. 21-2523).

Summary Authors

Averyn Lee (9/14/2020)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/17159994/parties/elim-romanian-pentecostal-church-v-pritzker/


Judge(s)

Easterbrook, Frank Hoover (Illinois)

Gettleman, Robert William (Illinois)

Attorneys(s) for Plaintiff

Gannam, Roger K. (Florida)

Leahu, Sorin A. (Illinois)

Mauck, John W. (Illinois)

Mihet, Horatio G. (Florida)

Schmid, Daniel Joseph (Florida)

Staver, Mathew D. (Florida)

Attorneys(s) for Defendant

Bauer, Kelly C. (Illinois)

Dworkin, Hal (Illinois)

Judge(s)

Easterbrook, Frank Hoover (Illinois)

Gettleman, Robert William (Illinois)

Attorneys(s) for Plaintiff

Gannam, Roger K. (Florida)

Leahu, Sorin A. (Illinois)

Mauck, John W. (Illinois)

Mihet, Horatio G. (Florida)

Schmid, Daniel Joseph (Florida)

Staver, Mathew D. (Florida)

Attorneys(s) for Defendant

Bauer, Kelly C. (Illinois)

Dworkin, Hal (Illinois)

Gallo, Sarah Jeanne (Illinois)

Gupta, Priyanka (Illinois)

Helfrich, Gretchen (Illinois)

Hunger, Sarah Ann (Illinois)

Newman, Sarah Hughes (Illinois)

Notz, Jane Elinor (Illinois)

Raoul, Kwame (Illinois)

Rees, R. Douglas (Illinois)

Wells, Christopher Graham (Illinois)

Wichern, Nadine J (Illinois)

Other Attorney(s)

Azmi, Nimra H. (District of Columbia)

Katskee, Richard B. (District of Columbia)

Luchenitser, Alexander Joseph (District of Columbia)

Morris, Hal R (Illinois)

Solomon, Benna R. (Illinois)

Documents in the Clearinghouse

Document

Docket [PACER]

Aug. 18, 2021 Docket
1-11

Verified Complaint for Declaratory Relief, Temporary Restraining Order, Preliminary and Permanent Injunctive Relief, and Damages (Part 3)

May 7, 2020 Complaint
1 (& 1-1 to 1-3)

Verified Complaint for Declaratory Relief, Temporary Restraining Order, Preliminary and Permanent Injunctive Relief, and Damages (Part 1)

May 7, 2020 Complaint
1-11 to 1-14

Verified Complaint for Declaratory Relief, Temporary Restraining Order, Preliminary and Permanent Injunctive Relief, and Damages (Part 4)

May 7, 2020 Complaint
1-3 to 1-11

Verified Complaint for Declaratory Relief, Temporary Restraining Order, Preliminary and Permanent Injunctive Relief, and Damages (Part 2)

May 7, 2020 Complaint
1-14 to 1-22

Verified Complaint for Declaratory Relief, Temporary Restraining Order, Preliminary and Permanent Injunctive Relief, and Damages (Part 5)

May 7, 2020 Complaint
5

Plaintiffs' Memorandum of Law in Support of Motion for Temporary Restraining Order and Preliminary Injunction

May 8, 2020 Pleading / Motion / Brief
18

Plaintiffs' Response in Opposition to Motion to Transfer Venue and Reassign Case

May 9, 2020 Pleading / Motion / Brief
21

The Governor's Opposition to Plaintiffs' Motion for Temporary Restraining Order and Preliminary Injunction

May 9, 2020 Pleading / Motion / Brief
25 (& 25-1 to 25-4)

Plaintiffs' Reply in Support Motion for Temporary Restraining Order and Preliminary Injunction

May 10, 2020 Pleading / Motion / Brief

Docket

See docket on RECAP: https://www.courtlistener.com/docket/17159994/elim-romanian-pentecostal-church-v-pritzker/

Last updated May 12, 2022, 8 p.m.

ECF Number Description Date Link
9

ORDER Third Amended General Order 20−0012 IN RE: CORONAVIRUS COVID−19 PUBLIC EMERGENCY Signed by the Chief Judge Rebecca R. Pallmeyer on April 24, 2020. All open cases are impacted by this Third Amended General Order. Parties are must carefully review all obligations under this Order, including the requirement listed in paragraph number 5 to file a joint written status report in most civil cases. See attached Order. Signed by the Honorable Rebecca R. Pallmeyer on 4/24/2020: Mailed notice (ec, ) (Entered: 05/08/2020)

April 24, 2020
1

COMPLAINT for Emergency Temporary Restraining Order and Preliminary Injunction filed by Elim Romanian Pentecostal Church, Logos Baptist Ministries; Filing fee $ 400, receipt number 0752−16996654. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V)(Mihet, Horatio) (Entered: 05/07/2020)

May 7, 2020
2

CIVIL Cover Sheet (Mihet, Horatio) (Entered: 05/07/2020)

May 7, 2020
3

Designation of Local Counsel by Elim Romanian Pentecostal Church, Logos Baptist Ministries (Mihet, Horatio) (Entered: 05/07/2020)

May 7, 2020
4

MOTION by Plaintiffs Elim Romanian Pentecostal Church, Logos Baptist Ministries for temporary restraining order and preliminary injunction and for emergency hearing (Mihet, Horatio) (Entered: 05/08/2020)

May 8, 2020
5

MEMORANDUM by Elim Romanian Pentecostal Church, Logos Baptist Ministries in support of motion for temporary restraining order 4 and for preliminary injunction and emergency hearing (Mihet, Horatio) (Entered: 05/08/2020)

May 8, 2020
6

MOTION by Plaintiffs Elim Romanian Pentecostal Church, Logos Baptist Ministries for leave to file excess pages in Memorandum in Support of Emergency Motion for Temporary Restraining Order and Preliminary Injunction Instanter (Mihet, Horatio) (Entered: 05/08/2020)

May 8, 2020
7

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752−16996711. (Mihet, Horatio) (Entered: 05/08/2020)

May 8, 2020
8

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752−16996713. (Schmid, Daniel) (Entered: 05/08/2020)

May 8, 2020

CASE ASSIGNED to the Honorable Robert W. Gettleman. Designated as Magistrate Judge the Honorable Jeffrey I. Cummings. Case assignment: Random assignment. (td, ) (Entered: 05/08/2020)

May 8, 2020
10

MINUTE entry before the Honorable Robert M. Dow, Jr: This matter is before Judge Dow as the emergency judge. Plaintiffs' motion for temporary restraining order and preliminary injunction [docket entry 769 on the emergency docket; docket entry 4 in the regular civil docket in Case No. 20−cv−2782] will be handled by Judge Gettleman, who is the assigned judge. The Clerk is directed to terminate the motion in the emergency docket and all further filings will be made in the regular civil docket. Counsel are directed to contact Judge Gettleman's Courtroom Deputy, Claire Newman (Claire_Newman@ilnd.uscourts.gov) with any inquiries. Mailed notice (cdh, ) (Entered: 05/08/2020)

May 8, 2020
12

ATTORNEY Appearance for Plaintiffs Elim Romanian Pentecostal Church, Logos Baptist Ministries by Sorin Adrian Leahu (Leahu, Sorin) (Entered: 05/08/2020)

May 8, 2020
13

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiffs have filed a motion for temporary restraining order ("TRO") and preliminary injunction 4 seeking to temporarily and preliminarily enjoin what plaintiffs refer to as defendant's "Gathering Orders" so that plaintiffs can begin conducting in−person religious services for more than 10 people beginning Sunday, May 10, 2020. Defendant is directed to file a response to the motion on or before 5:00 p.m., May 9, 2020. Plaintiffs may file a reply on or before 5:00 p.m., May 10, 2020. Due to the timing of the filing of the complaint and motion by plaintiffs (at approximately 11:15 p.m. May 7, 2020), and the briefing schedule set by the court, the court declines to issue a TRO with respect to this Sunday's May 10, 2020 religious services. The court will consider the remainder of the motion after receiving the parties' briefs. Plaintiffs' motion for leave to file excess pages in their memorandum of law in support of motion for temporary restraining order and preliminary injunction instanter 6 and attorneys Horatio G. Mihet 7 and Daniel J. Schmid's 8 motions to appear pro hac vice are granted. Mailed notice (cn). (Entered: 05/08/2020)

May 8, 2020
14

ATTORNEY Appearance for Defendant Jay Robert Pritzker by Kelly C. Bauer (Bauer, Kelly) (Entered: 05/08/2020)

May 8, 2020
15

ATTORNEY Appearance for Defendant Jay Robert Pritzker by Hal Dworkin (Dworkin, Hal) (Entered: 05/08/2020)

May 8, 2020
16

ATTORNEY Appearance for Defendant Jay Robert Pritzker by Christopher Graham Wells (Wells, Christopher) (Entered: 05/08/2020)

May 8, 2020
17

MOTION by Defendant Jay Robert Pritzker to transfer case and reassign as a related case (Wells, Christopher) (Entered: 05/08/2020)

May 8, 2020
18

RESPONSE by Elim Romanian Pentecostal Church, Logos Baptist Ministriesin Opposition to MOTION by Defendant Jay Robert Pritzker to transfer case and reassign as a related case 17 (Schmid, Daniel) (Entered: 05/09/2020)

May 9, 2020
19

ATTORNEY Appearance for Defendant Jay Robert Pritzker by Sarah Jeanne Gallo (Gallo, Sarah) (Entered: 05/09/2020)

May 9, 2020
20

MOTION by Defendant Jay Robert Pritzker for leave to file excess pages in opposition to Plaintiffs' motion for temporary restraining order and preliminary injunction (Rees, R.) (Entered: 05/09/2020)

May 9, 2020
21

RESPONSE by Jay Robert Pritzkerin Opposition to MOTION by Plaintiffs Elim Romanian Pentecostal Church, Logos Baptist Ministries for temporary restraining order and preliminary injunction and for emergency hearing 4 (Wells, Christopher) (Entered: 05/09/2020)

May 9, 2020
22

ATTORNEY Appearance for Defendant Jay Robert Pritzker by Sarah Hughes Newman (Newman, Sarah) (Entered: 05/09/2020)

May 9, 2020
23

ORDER Signed by the Honorable Robert W. Gettleman on 5/10/2020: For the reasons described in the attached ORDER, defendant's Motion to Transfer and Reassign Case (Doc. 17 ) is denied. Mailed notice (cn). (Entered: 05/10/2020)

May 10, 2020
24

MOTION by Plaintiffs Elim Romanian Pentecostal Church, Logos Baptist Ministries for leave to file excess pages instanter (Schmid, Daniel) (Entered: 05/10/2020)

May 10, 2020
25

REPLY by Plaintiffs Elim Romanian Pentecostal Church, Logos Baptist Ministries to motion for temporary restraining order 4 (Attachments: # 1 Exhibit A − Sixth Circuit Injunction Pending Appeal as to In−Person Gatherings, # 2 Exhibit B − Western District of Kentucky Injunction Pending Appeal Concerning In−Person Services, # 3 Exhibit C − Eastern District of Kentucky Temporary Restraining Order, # 4 Exhibit D − Supplemental Declaration of Pastor Cristian Ionescu)(Schmid, Daniel) (Entered: 05/10/2020)

May 10, 2020
27

REPLY by Plaintiffs Elim Romanian Pentecostal Church, Logos Baptist Ministries to motion for temporary restraining order 4 Amended Reply (Attachments: # 1 Exhibit A − Sixth Circuit Injunction Pending Appeal as to In−Person Gatherings, # 2 Exhibit B − Western District of Kentucky Injunction Pending Appeal Concerning In−Person Services, # 3 Exhibit C − Eastern District of Kentucky Temporary Restraining Order, # 4 Exhibit D − Supplemental Declaration of Pastor Cristian Ionescu)(Schmid, Daniel) (Entered: 05/10/2020)

May 10, 2020
28

MINUTE entry before the Honorable Robert W. Gettleman: The governor's motion for leave to file overlength brief instanter 20 , plaintiffs' motion for leave to file excess pages in their reply memorandum of law in support of motion for temporary restraining order and preliminary injunction instanter 24 , and plaintiffs' motion for leave to file corrected reply with table of contents and table of authorities 26 are granted. Mailed notice (cn). (Entered: 05/11/2020)

May 11, 2020
29

MINUTE entry before the Honorable Robert W. Gettleman: Defendant Governor J Pritzker is given leave to file a supplemental sur−reply on or before noon, May 12, 2020, responding to the additional factual and legal arguments contained in plaintiffs' amended reply brief 27 . No further briefs concerning the instant motion for a TRO and preliminary injunction will be accepted by the court. Mailed notice (cn). (Entered: 05/11/2020)

May 11, 2020
30

SUR−REPLY by Defendant Jay Robert Pritzker to text entry, 29 , motion for temporary restraining order 4 (Attachments: # 1 Exhibit Exhibit A − 5−10−20 Chicago Sun−Times Article)(Wells, Christopher) (Entered: 05/12/2020)

May 12, 2020

SUMMONS Issued as to Defendant Jay Robert Pritzker. (ng, ) (Entered: 05/12/2020)

May 12, 2020
31

MOTION by Plaintiffs Elim Romanian Pentecostal Church, Logos Baptist Ministries for leave to file Second Supplemental Declaration of Pastor Cristian Ionescu in Support of TRO/PI Motion (Attachments: # 1 Exhibit A − Second Supplemental Declaration of Pastor Cristian Ionescu in Support of TRO/PI Motion)(Mihet, Horatio) (Entered: 05/12/2020)

May 12, 2020
32

SUMMONS RETURNED EXECUTED filed by Plaintiffs Elim Romanian Pentecostal Church, Logos Baptist Ministries regarding Complaint, Motion for Temporary Restraining Order and Preliminary Injunction, Summons served on Governor Jay Robert Pritzker on 5/12/2020 (Schmid, Daniel) (Docket Text Modified by Clerks Office on 5/13/2020 (ec), ). (Entered: 05/13/2020)

May 13, 2020
33

MEMORANDUM Opinion and Order signed by the Honorable Robert W. Gettleman on 5/13/2020: Plaintiffs' motion for leave to file second supplemental declaration 31 is granted. For the reasons set forth in the attached Memorandum Opinion and Order, plaintiffs' motion for temporary restraining order and preliminary injunction (Doc. 4 ) is denied. Mailed notice (cn). (Entered: 05/13/2020)

May 13, 2020
34

NOTICE of appeal by Elim Romanian Pentecostal Church, Logos Baptist Ministries regarding orders 33 Filing fee $ 505, receipt number 0752−17009611. Receipt number: n (Schmid, Daniel) (Entered: 05/13/2020)

May 13, 2020
35

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752−17009707. (Attachments: # 1 Addendum − Courts Admitted)(Gannam, Roger) (Entered: 05/13/2020)

May 13, 2020
36

MOTION by Plaintiffs Elim Romanian Pentecostal Church, Logos Baptist MinistriesEmergency Injunction Pending Appeal (Mihet, Horatio) (Entered: 05/13/2020)

May 13, 2020
37

NOTICE of Appeal Due letter sent to counsel of record regarding notice of appeal 34 (ec, ) (Entered: 05/14/2020)

May 14, 2020
38

TRANSMITTED to the 7th Circuit the short record on notice of appeal 34 . Notified counsel (ec, ) (Entered: 05/14/2020)

May 14, 2020
40

ACKNOWLEDGMENT of receipt of short record on appeal regarding notice of appeal 34 ; USCA Case No. 20−1811 (ec, ) (Entered: 05/15/2020)

May 14, 2020
41

ORDER dated 5/16/2020 from the 7th Circuit regarding notice of appeal 34 ; Appellate case no.: 20−1811: Accordingly, IT IS FINALLY ORDERED that plaintiffs−appellants' motion to strike is DENIED. The defendant−appellee is GRANTED leave to file his overlength response, which was prepared and filed in less than 12 hours in accordance with this court's order. (ec,) (Entered: 05/19/2020)

May 19, 2020
42

ORDER ORDER Fourth Amended General Order 20−0012 IN RE: CORONAVIRUS COVID−19 PUBLIC EMERGENCY Signed by the Chief Judge Rebecca R. Pallmeyer on May 26, 2020. This Order does not extend or modify any deadlines set in civil cases. For non−emergency motions, no motion may be noticed for presentment on a date earlier than July 15, 2020. See attached Order. Signed by the Honorable Rebecca R. Pallmeyer on 5/26/2020: Mailed notice. (docket11, ) (Entered: 05/26/2020)

May 26, 2020
43

ATTORNEY Appearance for Defendant Jay Robert Pritzker by Gretchen Elizabeth Helfrich (Helfrich, Gretchen) (PDF not legible) Modified on 5/29/2020 (aee, ). (Entered: 05/28/2020)

May 28, 2020
44

NOTICE by Gretchen Elizabeth Helfrich of Change of Address (Helfrich, Gretchen) (Entered: 05/28/2020)

May 28, 2020
45

ATTORNEY Appearance for Defendant Jay Robert Pritzker by Gretchen Elizabeth Helfrich Refiled (Helfrich, Gretchen) (Entered: 05/29/2020)

May 29, 2020
46

MOTION by Defendant Jay Robert Pritzker to stay pending appeal (Wells, Christopher) (Entered: 06/02/2020)

June 2, 2020
47

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiffs are directed to respond to the Governor's motion to stay these proceedings pending appeal 46 on or before 6/8/2020; defendant may reply on or before 6/11/2020. The court will rule via CM/ECF. Mailed notice (cn). (Entered: 06/03/2020)

June 3, 2020
48

RESPONSE by Plaintiffs Elim Romanian Pentecostal Church, Logos Baptist Ministries to motion to stay 46 , set motion and R&R deadlines/hearings, 47 (Mihet, Horatio) (Entered: 06/04/2020)

June 4, 2020

State / Territory: Illinois

Case Type(s):

Speech and Religious Freedom

Special Collection(s):

COVID-19 (novel coronavirus)

Key Dates

Filing Date: May 7, 2020

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

Two churches in Illinois seeking injunction against the Governor's stay-at-home order and restoration plan preventing large gatherings

Plaintiff Type(s):

Non-profit religious organization

Attorney Organizations:

Legal Services/Legal Aid

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Governor of Illinois, State

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

Religious Freedom Rest. Act/Religious Land Use and Inst. Persons Act (RFRA/RLUIPA)

State law

Declaratory Judgment Act, 28 U.S.C. § 2201

Constitutional Clause(s):

Establishment Clause

Free Exercise Clause

Availably Documents:

Trial Court Docket

Complaint (any)

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Issues

General:

Disparate Treatment

Religious programs / policies

Discrimination-basis:

Religion discrimination