The raft of litigation concerning church shutdowns has been driven largely by evangelicals, many of whom have said that they do not agree with state regulation of public gatherings throughout the pandemic.

Since April, a series of churches have sued state and local governments because of restrictions on gatherings. The first wave of litigation came after many churches were not allowed to celebrate Easter and focused primarily on churches’ desire for drive-in services. The second wave rolled in as April ended when a number of states lengthened their shutdowns through May. The third wave, which does not consist of litigation at all, concerns a series of movements clamoring to reopen churches without government approval.