No. ______ In The Supreme Court of the United States SOUTH BAY UNITED PENTECOSTAL CHURCH AND BISHOP ARTHUR HODGES III, Petitioners, v. GAVIN NEWSOM, IN HIS OFFICIAL CAPACITY AS THE GOVERNOR OF CALIFORNIA, ET AL., Respondents. On Petition for a Writ of Certiorari to the United States Court of Appeals for the Ninth Circuit PETITION FOR WRIT OF CERTIORARI BEFORE JUDGMENT CHARLES S. LiMANDRI THOMAS BREJCHA Counsel of Record PETER BREEN PAUL M. JONNA THOMAS MORE SOCIETY JEFFREY M. TRISSELL 309 W. WASHINGTON ST., LIMANDRI & JONNA LLP STE. 1250 P.O. Box 9120 CHICAGO, IL 60606 Rancho Santa Fe, CA 92067 (312) 782-1680 (858) 759-9930
[email protected] HARMEET K. DHILLON Counsel for Petitioners MARK P. MEUSER South Bay United DHILLON LAW GROUP INC. Pentecostal Church and 177 POST ST., STE. 700 Bishop Arthur Hodges III SAN FRANCISCO, CA 94108 (415) 433-1700 i QUESTIONS PRESENTED Once again, Petitioners South Bay United Pentecostal Church and Bishop Arthur Hodges III (“South Bay”) must seek relief from this Court. California, in revising its reopening restrictions under a new “Blueprint” framework, exacerbates its discrimination and disparate treatment toward Places of Worship. While millions of Californians in a range of industries resumed business while observing mask-wearing and social distancing protocols, church services remain a disfavored activity in the eyes of the State and the County of San Diego. Similar scenarios playing out in other states generated a myriad of cases requesting stays and injunctions, several of which rose through appellate courts and were submitted to this Court for review. Lower courts are divided as to the constitutional standard for reviewing Free Exercise challenges to pandemic restrictions.