Amicus Brief

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Case: 3:20-cv-00075-GFVT Doc #: 16-1 Filed: 11/22/20 Page: 1 of 18 - Page ID#: 215

UNITED STATES DISTRICT COURT


EASTERN DISTRICT OF KENTUCKY
CENTRAL DIVISION AT FRANKFORT
CIVIL ACTION NO. 3:20-CV-00075-GFVT

DANVILLE CHRISTIAN ACADEMY, INC. PLAINTIFFS


and COMMONWEALTH OF KENTUCKY,
ex rel. Attorney General Daniel Cameron

v. AMICI CURIAE BRIEF OF PRIVATE RELIGIOUS SCHOOLS

ANDREW BESHEAR, in his official


capacity as the Governor of the Commonwealth of Kentucky DEFENDANT

*** *** ***

Amici file this brief in support of the Plaintiff’s Motion for a Temporary

Restraining Order and the Plaintiffs’ request for this Court’s ruling to apply

statewide. Each of the amici have been forced to close to in-person classroom

instruction under the Governor’s November 18, 2020 Executive Order.

The amici schools, Bourbon Christian Academy (in Paris), Foundation

Christian Academy (in Bowling Green), Heritage Christian School (in Owensboro),

Kentucky Christian Academy (in Campbellsville), Lexington Christian Academy,

Lexington Latin School, Somerset Christian School, Summit Christian Academy (in

Lexington), and Trinity Christian Academy (in Lexington) (the “Religious Schools”)

are private, religious schools throughout the Commonwealth that have been

offering safe in-person instruction in compliance with the Centers for Disease

Control and Prevention (“CDC”) social distancing guidelines since the start of the

academic year. The Religious Schools have followed the Governor’s and the

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Kentucky Department of Education’s Healthy at School guidelines. 1 Local health

departments have been consulted, made inspections, and been in continuous

contact. The Religious Schools have implemented measures that required a

substantial fiscal investment, which the schools gladly took to ensure the safety of

all members of their community. The Religious Schools, their administrators,

faculty, staff, parents, and students have done everything asked of them to remain

open for in-person instruction.

While the Religious Schools represent a variety of denominations within

Christianity, all the Religious Schools agree that “educating young people in their

faith, inculcating its teachings, and training them to live their faith are

responsibilities that lie at the very core of [their] mission.” 2 Like Danville Christian

Academy, all the amici Religious Schools believe that fulfillment of these

responsibilities requires in-person instruction to the greatest extent possible. Like

Danville Christian Academy, the Governor’s Order to cease in-person instruction

substantially burdens the free exercise of religion for each of the Religious Schools.

Like Danville Christian Academy, each of the Religious Schools desires to continue

in-person instruction in compliance with CDC social distancing guidelines.

Moreover, if the CDC were to revise its guidelines so that more is needed from the

Religious Schools, the Religious Schools would follow those guidelines if possible.

1 https://govstatus.egov.com/ky-healthy-at-school. Notably however, the Governor


has not clearly articulated a compelling state interest.
2 Our Lady of Guadalupe School v. Morrissey-Berru, 140 S. Ct. 2049, 2064 (2020).

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Because the Religious Schools believe both in the importance of their mission

and the need for in-person instruction to the greatest extent possible, each of the

Religious Schools has taken extraordinary steps and incurred significant financial

expense to provide safe in-person learning during this academic year. For example,

the Religious Schools have heavily invested in COVID precautions including

plexiglass barriers, personal protective equipment, sanitation equipment, physical

distancing screens and barriers, thermometers, additional desks and tables, Wi-Fi,

signage, and medical supplies. To that end, Trinity Christian Academy in Lexington

spent approximately $70,000; Lexington Christian Academy spent approximately

$392,000. Others like Somerset Christian School hired additional faculty to add

classes to ensure the students are socially distant while sitting in class and hired

additional staff whose sole daily responsibilities are the continual sanitizing of the

campus facilities.

Contrary to the implicit assumptions of the Governor’s Order, there is

absolutely no evidence that the current practices of the Religious Schools are

unsafe. Nor is there any evidence there will be widespread outbreaks of COVID if

the Religious Schools continue to offer in-person instruction in compliance with

CDC Guidelines and in compliance with the Commonwealth’s Healthy at School

guidelines. No evidence whatsoever has linked any current increase in COVID cases

to numbers in schools. In fact, on November 19, 2020, one day after the Governor’s

Executive Order, CDC Director Dr. Robert Redfield announced that schools do not

need to be closed and that schools are among the safest places for children to be

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during the coronavirus pandemic. Dr. Redfield stated: “[t]here is extensive data

[that] confirms...K-12 schools can operate with face-to-face learning and they can do

it safely and they can do it responsibly.” 3 And, all these schools closed down entirely

back in the spring, and remained closed all summer, so there is nothing to support

the assumption that if they close now, COVID numbers will suddenly go down.

ARGUMENT

The Religious Schools explicitly adopt all aspects of the arguments of the

Danville Christian Academy and the Attorney General. The Governor’s Executive

Order impermissibly burdens religious exercise and the other constitutional rights

of private, religious schools in Kentucky. True, the Governor has the best of

intentions to protect public health - an interest amici share and have demonstrated

over the last eight months through countless efforts to secure their own school

facilities, staff, faculty, and students, and the monies they have spent to that

endeavor. But the Governor has not pursued any compelling interest through the

least restrictive means as the Constitution requires. The reality is the Governor’s

public policy choice – shut down in-person learning to reduce the spread – has no

basis in the science of the virus or the social science of how children learn and

develop. The Religious Schools make five points that reinforce the arguments of the

Danville Christian School and the Attorney General.

3 https://www.c-span.org/video/?c4924557/cdc-director-redfield-data-supports-face-
face-learning-schools.

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1. The Governor’s arbitrary order to cease in-person


instruction is not based on “science.”

To the contrary, the “science” favors Danville Christian Academy. “A growing

body of research in the U.S. and Europe finds that because of safety procedures,

schools and child-care facilities aren’t major vectors of Covid-19 transmission.” 4

Indeed, according to researchers at Brown University tracking thousands of schools,

the “infection positivity rates of students at schools with in-person learning were

generally lower than the rates in the surrounding community.” 5 In New York City,

“[t]ens of thousands of children and staff have been tested for Covid-19, with a

reported case rate of only 0.19%. The school system is thus 15 times as safe as the

city at large, so it makes little sense to close the schools to fight a rising second

wave of infection.” 6

Although the United States lacks a national tracking system for school-based

cases, Spain’s decision to keep schools open during the nation’s second wave did not

increase the risk of transmission. 7 Amid Great Britain’s recent increased

restrictions and expanded “lock-down,” schools still remain open to in-person

instruction. “The World Health Organization advises that there have been only

4 Leslie Brody & Yoree Koh, Why Some Schools Close as Covid-19 Cases Rise When
Others Stay Open, WALL STREET JOURNAL (November 19, 2020) (available at
https://www.wsj.com/articles/why-some-schools-close-as-covid-19-cases-rise-when-
others-stay-open-11605789414).
5 Id.
6 Seth Barron, School’s Out for Autumn in New York, WALL STREET JOURNAL
(November 20, 2020) (available at https://www.wsj.com/articles/schools-out-for-
autumn-in-new-york-11605910005).
7 Brody and Koh, supra, note 5.

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limited cases of student-to-student transmission, and that school closures aren’t an

effective means of reducing community transmission.” 8

Not surprisingly, the American Academy of Pediatrics observes, “[t]he

importance of in-person learning is well documented and there is already evidence

of negative impacts on children because of school closures in the spring of 2020.” 9

In contrast, the Governor has not pointed to any evidence justifying his decision to

close the Religious Schools. The Religious Schools simply ask that they be allowed

to continue doing what they have been doing since the start of the academic year

and what the experts say is the best for the students.

2. The Governor’s Executive Order is inconsistent in how it


treats day-care centers and elementary schools.

According to the Governor’s Executive Order, day-care centers can continue

to operate and offer in-person instruction, but elementary schools cannot. Thus,

those Religious Schools that operate both an in-person elementary school and an in-

person pre-school day care center will have to close the former but can operate the

latter. A parent who has both a six-year-old and a four-year-old cannot send the six-

year-old to school but can send the four-year-old to pre-school. That makes no

8 Barron, supra, note 7; see also https://www.who.int/docs/default-


source/coronaviruse/risk-comms-updates/update39-covid-and-
schools.pdf?sfvrsn=320db233_2 (finding “[i]n most infections or COVID-19 cases
reported in children, infection was acquired at home”).
9 American Academy of Pediatrics, COVID-19 PLANNING CONSIDERATIONS:
GUIDANCE FOR SCHOOL REENTRY (2020) (available at
https://services.aap.org/en/pages/2019-novel-coronavirus-covid-19-infections/clinical-
guidance/covid-19-planning-considerations-return-to-in-person-education-in-
schools/).

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sense. 10 Moreover, some licensed childcare facilities are offering in-person childcare

for school age children that simply amounts to the supervision of virtual instruction

or some in-person instruction. This is perfectly legal under the Governor’s

inconsistent Executive Order despite that it involves the same types of in-person

contacts that in-person instruction in schools would involve.

3. The Governor’s Executive Order implicitly assumes that


in-person is unsafe, but also assumes that other activities
involving thousands of people indoors are perfectly safe.

In a show of inconsistency, the Governor’s Executive Order operates on the

implicit assumption that in-person educational instruction is unsafe, while

inconsistently permitting other indoor activities involving thousands of people. For

example, the Governor has declared that college sporting events are exempt from

his order if the organizers follow social distancing practices. Therefore, the

University of Kentucky will be able to have 3,000 people (15% capacity) in Rupp

Arena for college basketball games, but the Religious Schools must close. Similarly,

cinemas will be able to offer in-person movies where twenty-five total strangers sit

in a room for two hours. While the Religious Schools do not doubt the ability of the

University of Kentucky to safely have fans in Rupp Arena or for cinemas to have

twenty-five total for a movie, the reality is there is no evidence as to the safety of

these activities. In contrast, the Religious Schools, which generally have classes

well below twenty-five students and where the students are around the same people

10 Indeed, such arbitrary distinctions would not even survive rational basis review,
let alone the strict scrutiny applied to the free exercise of religion.

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every day, as opposed to having contact with thousands of strangers, have proved

that they can operate safely.

4. Closing religious schools defies health experts’ guidance.

As cited above, the day after the Governor’s Executive Order, the CDC

announced schools should remain open and are among the safest places for children

right now, all of which the CDC says is supported by “extensive data.” Research

further demonstrates distance learning is less effective than in-person instruction,

distance learning can be harmful to children’s development, and in-person learning

poses minimal risks for children, who are less likely to contract or transmit COVID-

19.

Studies show that students using a distance learning model underperform

compared to students learning in-person. In 2019, the National Education Policy

Center found that only 48.5% of virtual schools received acceptable performance

ratings, with an average graduation rate of 50.1%, “far short of the national average

of 84%.” 11 The Center for Research on Education Outcomes at Stanford University

(“CREDO”) conducted a similar study comparing distance learning students with

similar students attending in-person classes. Compared to the in-person students,

virtual students showed significantly weaker academic performance. 12

Distance learning impedes the development of younger children. “In grades

K-3, children are still developing the skills to regulate their own behavior, emotions,

11Alex Molnar, Nat’l Educ. Pol’y Ctr., Virtual Schools in the U.S. 2019, at 9 (May
2019), https://bit.ly/33YNJ7I.
12James L. Woodworth et al., Ctr. for Research on Educ. Outcomes, Online Charter
School Study 23 (2015), https://stanford.io/34gu2sj.

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and attention, and therefore struggle with distance learning.” 13 Most distance-

learning models rely on increased levels of parental involvement, which imposes

unique burdens upon single parents or low-income families with two working

parents, and on families with limited internet access which is the case for many in

rural parts of Kentucky. 14

Most distance learning also requires increased “screen time” that has proven

harmful to children. According to the National Institutes of Health, “children who

spent more than two hours a day on screen-time activities scored lower on language

and thinking tests,” and children who spent more than seven hours a day on a

screen “experienced thinning of the brain’s cortex, the area of the brain related to

critical thinking and reasoning.” 15

The problems with distance learning apply with equal or greater force to

religious instruction. As described above, amici operate as a religious school because

religious instruction is infused throughout the school day, including during non-

instructional time. Teachers and staff model religious behavior inside and outside

the classroom, in the lunchroom, and on the playground and playing fields.

Students congregate together in a religious manner for chapel services, prayer,

13News Release, Nat’l Acads. of Scis., Eng’g, & Med., Schools Should Prioritize
Reopening in Fall 2020, Especially for Grades K-5, While Weighing Risks and
Benefits (July 15, 2020), https://perma.cc/6QHC-4FYV.
14See, e.g., 2015 Mathematica Policy Research Report (showing that 78 percent of
online charter elementary schools “expect parents to actively participate in the
student’s instruction”) Brian Gill et al., Mathematica Pol’y Research, Inside Online
Charter Schools 22- 23(Oct. 2015), https://bit.ly/2Y52F0p.
15Jennifer F. Cross, What Does Too Much Screen Time Do to Children’s Brains?,
Health Matters (2020), https://bit.ly/3mrTUYK.

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scripture study, and religious education, all of which are foundational to concepts

and doctrines of Christian community. These are just some of the many aspects of

Christian community and of Christian education that amici believe cannot be

adequately sustained online.

Distance learning has negatively impacted children during the COVID-19

pandemic. News reports have described distance learning as an unmitigated

disaster that has been terrible for children due to technological problems, limited

student engagement, and screen time vastly exceeding what health experts

recommend as safe for children. 16 Recent research reveals troubling trends

resulting from schools’ transition to distance learning in the spring of 2020. The

University of Washington’s Center on Reinventing Public Education reported that,

after surveying 477 school districts that provided distance learning as a result of

the pandemic: “[J]ust one in three districts expect teachers to provide instruction,

track student engagement, or monitor academic progress for all students…. Far too

many districts are leaving learning to chance during the coronavirus closures.” 17

Another study found that due to school closures in the Spring of 2020, students’

academic achievement would likely be restricted to only “63–68% of the learning

gains in reading relative to a typical school year,” and only “37–50% of the learning

16Bethany Mandel, ‘Remote Learning’ is a disaster, and terrible for children, THE
NEW YORK POST, (Sept. 16, 2020), https://bit.ly/3hZ2vOY.
17 Betheny Gross & Alice Opalka, Ctr. on Reinventing Pub. Educ., Too Many
Schools Leave Learning to Chance During the Pandemic, at p. 1 (June 2020),
https://bit.ly/3kesOSS.

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gains in math.” 18 Yet another study found that students who receive online learning

during the upcoming fall semester will lose “three to four months of learning” by the

start of 2021, compared to students receiving in-person education. 19

The reduced effectiveness of distance learning restricts students’ religious

education to the same degree as students’ secular education. Experts throughout

the scientific community overwhelmingly support re-opening schools, including the

CDC. 20

Dr. Anthony S. Fauci, the Director of the National Institute of Allergy and

Infectious Diseases, encouraged that the “default position should be to try, as best

as you possibly can, to open up the schools for in-person learning … because of the

psychological benefit and in some places, even for the nutrition of children[.]” 21

According to the CDC, in-person instruction is critical for students’ development

because “[s]chools play a critical role in supporting the whole child, not just their

academic achievement,” but also “development of social and emotional skills,”

“creat[ing] a safe environment for learning; address[ing] nutritional needs; and

18 Megan Kuhfeld et al., Projecting the Potential Impacts of COVID-19 School


Closures on Academic Achievement, at p. 2 (Brown Univ. Annenberg Inst., Paper
No. 20-226, May 2020), https://bit.ly/2FHPvA4.
19Emma Dorn et al., McKinsey & Company, COVID-19 and Student Learning in the
United States: The Hurt Could Last a Lifetime, at p. 3 (June 2020),
https://mck.co/3kKUnV0.
20Ctrs. for Disease Control & Prevention, The Importance of Reopening America’s
Schools This Fall, https://perma.cc/6ZUL-6EQA.
Mark Pazniokas, In Connecticut Briefing, Fauci Urges a Return to Classroom, CT
21

MIRROR (Aug. 3, 2020), https://bit.ly/3hzrlon.

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facilitat[ing] physical activity.” 22 Nevertheless, especially in light of such evidence,

the amici are deeply concerned that the secular state (via the Governor’s office) is

choosing which methods are best for accomplishing their religious mission. And the

method the Governor has imposed on the Religious Schools is not sufficiently

justified by the science.

5. The Executive Order burdens religious exercise.

Like Danville Christian Academy, in-person education is essential for the

amici schools’ free exercise of religion. Their mission is to teach students what it

means to be a disciple of Jesus Christ, not only through classroom education, but

also through prayer, worship, and religious formation that occurs in-person. The

Religious Schools firmly and sincerely believe the Bible requires Christians to

gather together in order to practice the Christian faith and to learn how to be a

disciple of Jesus Christ, and that much of Christian formation occurs through

Christian community. For instance, these schools have devotions and services which

involve corporate worship, prayer, scripture meditation, and religious education.

Amici believe they cannot effectively provide a Christian education to their students

if the students are not able to meet in-person. Amici teachers, staff, and students

engage in prayer daily. These times of prayer allow students to share their worries

and fears with teachers, and to receive encouragement and religious formation

through the ministry of prayer. Amici believe a prayer ministry is ineffective in a

distance learning environment. Yet the Governor’s Order dictates to the Religious

22Ctrs. for Disease Control & Prevention, The Importance of Reopening America’s
Schools This Fall, https://perma.cc/6ZUL-6EQA.

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Schools which methods they must use in carrying out their mission and developing

Christian community.

The Governor’s efforts to stop COVID are well-intentioned, as is every like-

minded governmental official in the world. But the Constitution provides limits

even when the outcome is difficult or unpopular. “It would be easy to put [the

Constitution] on the shelf in times like this, to be pulled down and dusted off when

more convenient. But that is not our tradition. Its enduring quality requires that it

be respected even when it is hard.” 23

Closing these private, religious schools infringes on the right of amici to

provide religious instruction to its students, the right of parents to pursue religious

education for their children, and the right of students to receive religious

instruction. The Executive Order is not generally applicable because it does not

apply to equivalent operations where persons outside of one household are inside

such as preschools, movie theaters, college basketball arenas and shopping malls.

Of course the Governor has an interest in safeguarding public health generally, but

that interest must specifically and narrowly apply to the closure of in-person

attendance at private, religious schools and it fails to do so. The U.S. Supreme

Court’s analysis in Hurley v. Irish-American Gay, Lesbian & Bisexual Group of

Boston 24 is instructive on this point. In that case, the Court did not evaluate the

government’s general interest in preventing discrimination, but its particular

23Tabernacle Baptist Church, Inc. of Nicholasville v. Beshear, 459 F. Supp. 3d 847,


856 (E.D. Ky. 2020).
24 515 U.S. 557, 578-579 (1995).

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interest in forcing a specific organization to facilitate the message of an advocacy

group. 25 There, as here, the apparent purpose of applying the law under those

circumstances was “simply to require [the organization] to modify [its conduct].” 26

But such an interest—which “allow[s] exactly what the [First Amendment]

forbids,” 27—is not even legitimate, much less compelling.

The Governor, moreover, has no significant interest in forcing private,

religious schools to close when so many exceptions are made for other places where

the public can gather. By allowing these exemptions, the Governor has

demonstrated that he inconsistently pursues the interest in stopping the spread of

the virus. Such an inconsistently pursued objective undermines its compelling

nature because “a law cannot be regarded as protecting an interest of the highest

order when it leaves appreciable damage to that supposedly vital interest

unprohibited.” 28

The closing of private, religious schools is also not narrowly tailored to the

state’s interest in preventing the spread of COVID-19. The CDC, the AAP, and

other public health organizations have endorsed in-person instruction for the 2020–

21 school year, and have outlined measures that would ensure public safety while

also providing students with the educational developmental benefit of in-person

education. The state itself has crafted social distancing guidelines and other

25 Id., at 578.
26 Id.
27 Id.
28 Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520, 547
(1993) (quotation marks and alterations omitted).

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preventative measures that allow schools, childcare facilities, and institutions of

higher education to safely conduct in-person operations. Those measures, among

others, are more narrowly tailored than the blanket closure order imposed here.

Special exceptions and less restrictive regulations imposed on other public places,

childcare facilities, and institutions of higher education demonstrate that the

Defendant could prevent the transmission of COVID-19 through less restrictive

means that do not infringe on fundamental constitutional rights. Therefore, the

Court should enter judgment in favor of Plaintiffs and declare that the Executive

Order closing private, religious schools violates the First Amendment to the United

States Constitution and KRS 446.350.

While the state has discretion to implement safety restrictions, it must do so

neutrally toward religious institutions. “[R]estrictions inexplicably applied to one

group and exempted from another do little to further these goals and do much to

burden religious freedom.” 29 The Sixth Circuit previously affirmed this Court’s

holding on the unconstitutionality of the Governor’s prior executive orders on

church services. There, the Court asked:

Assuming all of the same precautions are taken, why is it safe to wait
in a car for a liquor store to open but dangerous to wait in a car to hear
morning prayers? Why can someone safely walk down a grocery store
aisle but not a pew? And why can someone safely interact with a brave
deliverywoman but not with a stoic minister? 30

In that same vein, assuming these religious schools are following all the CDC

recommended precautions, why is it safe to go to the theater and watch a movie, but

29 Maryville Baptist Church, Inc. v. Beshear, 957 F.3d 610, 614–15 (6th Cir. 2020).
30 Id.

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not school and hear religious instruction? Why can someone safely sit at an office

desk but not a school desk? Why can someone safely interact with a store clerk but

not their teacher? As before the Sixth Circuit earlier this year, “[t]he

Commonwealth has no good answers. While the law may take periodic naps during

a pandemic, we will not let it sleep through one.” 31

And it is no answer for the Governor to argue since all schools are closed,

closing religious schools does not burden religious exercise in violation of the

Constitution and the Kentucky RFRA. The appropriate inquiry is not whether all

schools are closed. 32 Instead, the inquiry is why religious schools are placed in the

disfavorable category when other public places are not. 33

In making that analysis, the Court should answer four questions: (1) does

this Executive Order favor some organizations?; (2) are religious organization in the

disfavored category?; (3) why?; and (4) is that reason a sufficient justification for the

differential treatment and the disfavoring of religion? This Executive Order clearly

creates two categories of public places. Some places are allowed to remain open:

retail stores, business offices. But some places must shut their doors: restaurants,

31 Id.
32Laycock & Collis, Generally Applicable Law and the Free Exercise of Religion, 95
NEB. L. REV. 1, 22 (2016) (The inquiry “is not whether one or a few secular analogs
are regulated. The question is whether a single secular analog is not regulated”).
33Employment Div., Dept. of Human Resources of Ore. v. Smith, 494 U.S. 872, 884
(1990) (“where the State has in place a system of individual exemptions, it may not
refuse to extend that system to cases of religious hardship without compelling
reason”). Moreover, “Smith involved government regulation of only outward
physical acts,” but this case “concerns government interference with an internal
church decision that affects the faith and mission of the church itself.” Hosanna-
Tabor Evangelical Lutheran Church & Sch. v. E.E.O.C., 565 U.S. 171, 190 (2012).

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schools. Churches may remain open. Preschools may remain open (including

preschools located at these amici). But K-12 private religious schools must close to

in-person education.

The Governor has provided no reason for the restrictions placed on religious

schools. There is no evidence or logic why these restrictions are necessary for

religious schools, especially with a several month history of the lack of any COVID

spread from CDC-compliant schools like Plaintiff, amici, and scores of others in

Kentucky. The Executive Order shuttering religious schools does not even pass a

rational basis review, let alone the strict scrutiny applied under the First

Amendment and Kentucky RFRA.

For the reasons above and those stated in the briefs of Danville Christian

Academy and the Attorney General, the Motion for Temporary Restraining Order

should be granted.

Respectfully submitted

/s/ Bryan H. Beauman


Bryan H. Beauman
Sturgill, Turner, Barker & Moloney PLLC
333 West Vine Street, Suite 1500
Lexington, Kentucky 40507
Telephone: 859.255.8581
Facsimile: 859.231.0851
[email protected]
COUNSEL FOR AMICI CURIAE

and

Gregg Thornton
Ward, Hocker & Thornton PLLC
Vine Center
333 West Vine Street, Suite 1100

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Lexington, Kentucky 40507


Telephone: 859.422.6000
Facsimile: 859.422.6001
[email protected]
COUNSEL FOR LEXINGTON CHRISTIAN
ACADEMY

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