Rev. Kevin Robinson and Rabbi Yisrael A. Knopfler v. Philip D. Murphy, Gov. of the State of New Jersey

In Rev. Kevin Robinson and Rabbi Yisrael A. Knopfler v. Philip D. Murphy, Governor of New Jersey, a Catholic priest and an Orthodox Jewish rabbi challenged the state's COVID-19 executive orders restricting religious gatherings. The lawsuit targeted Executive Order 107 and Administrative Order 2020-4, which banned gatherings exceeding 10 people, effectively limiting Catholic Masses to seven attendees and preventing Jewish minyans requiring 10 men. Plaintiffs alleged violations of the Free Exercise Clause, Free Speech, Assembly, Equal Protection, Establishment Clause, and ultra vires state action under the Fourteenth Amendment.

The restrictions stemmed from incidents including police interrupting an outdoor synagogue prayer in Lakewood on April 13, 2020, causing worshippers to flee, and threatening arrest at Saint Anthony of Padua Church in North Caldwell on March 20, 2020. Later orders capped houses of worship at 25% capacity or 150 people, while allowing secular venues like schools and retail up to 100% or 50%. A mask mandate permitted open-ended secular exemptions but limited religious ones to brief removals.

The District Court denied preliminary injunctive relief on October 2, 2020, applying rational basis review and finding no likelihood of success. After the Third Circuit denied relief, plaintiffs appealed to the Supreme Court. On December 15, 2020, the Court granted certiorari before judgment, vacated the District Court's order, and remanded for reconsideration in light of Roman Catholic Diocese of Brooklyn v. Cuomo, emphasizing neutral treatment of religious activities. New Jersey subsequently amended orders to 50% capacity for worship sites. The case was stayed pending further Supreme Court guidance on COVID-19 challenges.