In Hawse v. Page, (8th Cir., July 30, 2021), the U.S. 8th Circuit Court of Appeals, in a 2-1 decision, dismissed on standing and mootness grounds challenges to St. Louis County, Missouri’s now-superseded COVID-related limit on the number of persons who could attend church services. The majority said in part:
Whether or not the churches were formally closed in April 2020, the complaint is bereft of an allegation that but for the Order, the churches attended by the appellants would have allowed groups of ten or more persons to gather in the early weeks of the pandemic.
Judge Stras filed a dissenting opinion.