Verified Complaint — Calvary Chapel of Bangor v. Mills

Record facts

UNITED STATES DISTRICT COURT · No. 1:20-cv-00156-NT · Doc. 1 · 2020-05-05 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
DISTRICT OF MAINE  
Bangor Division 
 
CALVARY CHAPEL OF BANGOR, 
) 
 
 
 
 
 
 
) 
 
 
 
Plaintiff, 
 
) 
 
 
 
 
 
 
) 
v. 
 
 
 
 
 
) 
Case No. ________________ 
 
 
 
 
 
 
) 
JANET MILLS, in her  
 
 
) 
official capacity as Governor of the   
) 
State of Maine, 
 
 
 
) 
 
 
 
 
 
 
) 
 
 
 
Defendant. 
 
) 
VERIFIED COMPLAINT FOR DECLARATORY RELIEF,  
TEMPORARY RESTRAINING ORDER, PRELIMINARY AND  
PERMANENT INJUNCTIVE RELIEF, AND DAMAGES 
 
 
For its Verified Complaint against Defendant, JANET MILLS, in her official capacity as 
Governor of the State of Maine (“Governor Mills” or the “State”), Plaintiff, CALVARY CHAPEL 
OF BANGOR (“Calvary Chapel”), alleges and avers as follows: 
URGENCIES JUSTIFYING TEMPORARY RESTRAINING ORDER 
1. 
In its Prayer for Relief, infra, and in the contemporaneously filed Motion for 
Temporary Restraining Order (TRO), Calvary Chapel seeks a TRO restraining enforcement 
against Calvary Chapel of the various COVID-19 orders issued by Governor Mills and other State 
officials purporting to prohibit Calvary Chapel, on pain of criminal sanctions, from gathering in-
person at Calvary Chapel for worship services, regardless of the number of individuals present or 
whether Calvary Chapel meets or exceeds the social distancing and hygiene guidelines pursuant 
to which the State disparately and discriminatorily allows so-called “essential” commercial and 
non-religious entities (e.g., liquor stores, marijuana dispensaries, warehouse clubs, and ‘big box’ 
stores) to accommodate large crowds and masses of persons without scrutiny or numerical limit. 
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2. 
As shown in the verified allegations below, Governor Mills’ Executive Orders 
relating to COVID-19 have been interpreted, applied, and enforced, including against the pastor 
of Calvary Chapel, such that Pastor Ken Graves (“Pastor Graves”) has been forced not to hold 
in-person religious services at the Church and to prohibit his members from attending their house 
of worship. 
3. 
At around the same time as Governor Mills’ Executive Orders surrounding 
COVID-19 were being used to threaten criminal sanctions on Calvary Chapel’s pastor, officials in 
other jurisdictions had similarly threatened to impose criminal sanctions on other religious 
gatherings. In Louisville, Kentucky, for example, the government threatened to use police to 
impose criminal sanctions on those individuals found in violation of similar COVID-19 orders and 
threatened to impose various sanctions on individuals found in violation of such orders. The United 
States District Court for the Western District of Kentucky found that the mere threat of such 
criminal sanction warranted a TRO. See On Fire Christian Center, Inc. v. Fischer, No. 3:20-cv-
264-JRW, 2020 WL 1820249 (W.D. Ky. Apr. 11, 2020) [hereinafter On Fire]. The On Fire TRO 
enjoined the Mayor of Louisville from “enforcing, attempting to enforce, threatening to 
enforce, or otherwise requiring compliance with any prohibition on drive-in church services 
at On Fire.” Id. at *1 (emphasis added). 
4. 
In fact, the Maine State Police—acting under the direction of Governor Mills’ 
orders—have publicly declared that they would enforce the Governor’s orders and have threatened 
to impose criminal sanctions on those found in violation of them. 
5. 
Additionally, the Governor of Kansas had imposed a similar restriction on religious 
gatherings in Kansas, stating that “gatherings” of more than 10 individuals are prohibited, 
including religious gatherings. On April 18, 2020, the United States District for the District of 
Kansas issued a TRO enjoining Kansas officials from enforcing its discriminatory prohibition on 
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religious gatherings and required the government to treat “religious” worship services the same as 
other similar gatherings that are permitted. See First Baptist Church. v. Kelly, No. 20-1102-JWB, 
2020 WL 1910021, *6–7 (D. Kan. Apr. 18, 2020) [hereinafter First Baptist]. The First Baptist 
TRO specifically stated that the government’s disparate treatment of religious gatherings was a 
violation of the Free Exercise Clause because it showed that “religious activities were specifically 
targeted for more onerous restrictions than comparable secular activities,” and that the 
churches had shown irreparable harm because they would “be prevented from gathering for 
worship at their churches” during the pendency of the executive order. Id. at *7–8 (emphasis 
added). 
6. 
In discussing the Kansas orders—which imposed a 10-person limit on in-person 
gatherings, which is onerous but still not as restrictive as Governor Mills’ orders—the court said 
that specifically singling out religious gatherings for disparate treatment while permitting other 
non-religious activities “show[s] that these executive orders expressly target religious gatherings 
on a broad scale and are, therefore, not facially neutral,” First Baptist, 2020 WL 1910021, at *7, 
and—much like here—“churches and religious activities appear to have been singled out among 
essential functions for stricter treatment. It appears to be the only essential function whose core 
purpose—association for the purpose of worship—had been basically eliminated.” Id. 
(emphasis added). Thus, the court found that a TRO was necessary and that Kansas should be 
enjoined from enforcing its orders’ disparate terms against churches. Indeed, “it goes without 
saying that the government could not lawfully expressly prohibit individuals from meeting 
together for religious services.” Id. at *6 (emphasis added). 
7. 
Additionally, the Sixth Circuit of Appeals has issued an Emergency Injunction 
Pending Appeal prohibiting the Governor from enforcing prohibitions on religious worship 
services. See Maryville Baptist Church, Inc. v. Beshear, -- F.3d --, No. 20-5427, 2020 WL 2111316 
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(6th Cir. May 2, 2020). In that appeal challenging orders similar to Governor Mills’ orders here, 
the Sixth Circuit stated that “[t]he Governor’s actions substantially burden the congregants’ 
sincerely held religious practices—and plainly so. . . . Orders prohibiting religious gatherings, 
enforced by police officers telling congregants they violated a criminal law and by officers 
taking down license plate numbers, amount to a significant burden on worship gatherings.” 
2020 WL 2111316, at *2 (emphasis added). Additionally, “[t]he way the orders treat comparable 
religious and non-religious activities suggests that they do not amount to the least restrictive way 
of regulating the churches.” Id. “Outright bans on religious activity alone obviously count. So do 
general bans that cover religious activity when there are exceptions for comparable secular 
activities.” Id., at *3. In discussing the prohibitions on religious gatherings, the Sixth Circuit posed 
several questions of equal import here:  
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? The Commonwealth has no good answers. While the law may take 
periodic naps during a pandemic, we will not let it sleep through one. 
Id., at *4 (emphasis added). 
8. 
Because the prohibition on religious gatherings substantially burdened Maryville 
Baptist’s sincerely held religious beliefs and was not the least restrictive means, the Sixth Circuit 
concluded the plaintiff church and pastor were likely to succeed on the merits of their free exercise 
claims as to both in-person and drive-in services. Id., at *2–3. Balancing the remaining injunction 
factors, the court issued an injunction pending appeal enjoining the Governor of Kentucky from 
enforcing his unconstitutional orders against drive-in services, and directed the district court to 
prioritize consideration of enjoining in-person services, with the admonition, “The breadth of the 
ban on religious services, together with a haven for numerous secular exceptions, should give 
pause to anyone who prizes religious freedom.” Id., at *5. 
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9. 
Calvary Chapel’s members were also threatened with criminal sanctions and 
penalties if, at any time, any number of individuals gathered together for in-person worship 
services at Calvary Chapel, and regardless of whether social distancing, enhanced sanitization, and 
personal hygiene practices were followed. Because of the government threat of criminal sanction, 
Calvary Chapel was forced not to host services on Easter Sunday, the most treasured day in 
Christianity. 
10. 
Absent emergency relief from this Court, Calvary Chapel, its pastor, and all 
congregants will suffer immediate and irreparable injury from the threat of criminal prosecution 
for the mere act of engaging in the free exercise of religion and going to church. Indeed, if Calvary 
Chapel, its pastor, or its congregants do not subscribe to what Governor Mills’ has 
prescribed as orthodox in a worship service, they risk becoming criminals in the State. A 
temporary restraining should issue. 
INTRODUCTION 
11. 
Due to the unprecedented nature of the 2019 novel coronavirus disease 
(COVID-19) and the indisputable health tragedy the disease has wrought on our great Republic 
and those victims suffering under its yoke, there are those who may find it “tempting to hold that 
First Amendment rights should acquiesce to national security in this instance.” Tobey v. Jones, 
706 F.3d 379, 393 (4th Cir. 2013). One could be forgiven for hastily reaching such a conclusion 
in such uncertain times, but “our Forefather Benjamin Franklin warned against such a temptation 
by opining that those who can give up essential liberty to obtain a little temporary safety, deserve 
neither liberty nor safety.” Id.  
12. 
When the great American experiment was first implemented, our revered Founders 
took pains to note that the Constitution—and all of the rights it recognized and enshrined—was 
instituted “in order to form a more perfect Union, establish Justice, insure domestic Tranquility, 
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provide for the common defense, promote the general Welfare, and secure the Blessings of 
Liberty to ourselves and our Posterity.” U.S. Const. Pmbl. (emphasis added). To this very day, 
“we continue to strive toward ‘[that] more perfect union.’” Smith v. City of New Smyrna Beach, 
No. 6:110cv01110-Orl-37KRS, 2013 WL 5230659, *1 (M.D. Fla. Sept. 16, 2013). That work is 
not easy, and governments acting in good faith can and sometimes do miss the mark. This is such 
a case.  
13. 
Recognizing that times of crisis would arise, that such times might lead 
governments to seek to repress precious freedoms, and that the Republic’s survival depended upon 
defeating such repressive instincts, the genius of our founding document is that it placed explicit 
protections into the text of the Bill of Rights. And, importantly, “[o]ur Bill of Rights placed our 
survival on firmer ground—that of freedom, not repression.” Konigsberg v. State Bar of 
California, 366 U.S. 36, 79 (1961) (Black, J., dissenting).  
14. 
During times of national crisis, such as the current uncertainty arising from 
COVID-19, “the fog of public excitement obscures the ancient landmarks set up in our Bill of 
Rights.” American Communist Ass’n, C.I.O. v. Douds, 339 U.S. 382, 453 (1950) (Black, J., 
dissenting). But, where the fog of public excitement is at its apex, “the more imperative is the need 
to preserve inviolate the constitutional rights of free speech, free press and free assembly.” De 
Jonge v. Oregon, 299 U.S. 353, 365 (1937). Without doubt, “[t]herein lies the security of the 
Republic, the very foundation of constitutional government.” Id. 
15. 
It is beyond cavil that our commitment to our founding principles is most tested 
and best calculated during times of crisis and uncertainty. Indeed, “[t]imes of crisis take the truest 
measure of our commitment to constitutional values. Constitutional values are only as strong as 
our willingness to reaffirm them when they seem most costly to bear.” Hartness v. Bush, 919 
F.2d 170, 181 (D.C. Cir. 1990) (Edwards, J., dissenting) (emphasis added). Our willingness to 
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reaffirm our staunch commitment to our fundamental freedoms is imperative to the very survival 
of the American experiment. For, “[h]istory reveals that the initial steps in the erosion of individual 
rights are usually excused on the basis of an ‘emergency’ or threat to the public. But the ultimate 
strength of our constitutional guarantees lies in the unhesitating application in times of crisis 
and tranquility alike.” United States v. Bell, 464 F.2d 667, 676 (2d Cir. 1972) (Mansfield, J., 
concurring) (emphasis added). 
16. 
Calvary Chapel brings this case to restrain the troubling transgression of its 
fundamental and cherished liberties wrought by the imposition of Governor Mills’ orders 
surrounding COVID-19. Calvary Chapel seeks not to discredit or discard the government’s 
unquestionable interest in doing that task for which it was instituted—protecting the citizenry. But, 
as is often true in times of crisis, Calvary Chapel respectfully submits that in an effort to uphold 
her sworn duties Governor Mills has stepped over a line the Constitution does not permit. Because 
of that, Calvary Chapel brings this action to ensure that this Court safeguards the cherished liberties 
for which so many have fought and died. For, “[i]f the provisions of the Constitution be not 
upheld when they pinch as well as when they comfort, they may as well be discarded.” Home 
Bldg. & Loan Ass’n v. Blaisdell, 290 U.S. 398, 483 (1934) (Sutherland, J., dissenting) (emphasis 
added). Calvary Chapel prays unto the Court that it not permit the cherished and fundamental 
liberties enshrined in the Constitution to be another tragic casualty of COVID-19. 
PARTIES 
17. 
Plaintiff, CALVARY CHAPEL OF BANGOR (“Calvary Chapel” or the 
“Church”), is a non-profit corporation incorporated under the laws of the State of Maine with its 
principal place of business at 154 River Road Orrington, Maine 04474. 
18. 
Defendant, JANET MILLS, in her official capacity as Governor of the State of 
Maine  (“Governor Mills” or the “State”), is responsible for enacting and enforcing the COVID-19 
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Executive Orders and other Orders at issue in this litigation. Governor Mills is sued in her official 
capacity. 
JURISDICTION AND VENUE 
19. 
This action arises under the First and Fourteenth Amendments to the United States 
Constitution and is brought pursuant to 42 U.S.C. § 1983. This action also arises under the 
Religious Land Use and Institutionalized Persons Act, 42 U.S.C. §2000cc, et seq. This action also 
arises under Article I, Sections 3, 4, and 13 the Constitution of Maine.  
20. 
This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1331, 1343, 
and 1367. 
21. 
Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b)(2) because a 
substantial part of the events or omissions giving rise to Calvary Chapel’s claims occurred in this 
district. 
22. 
This Court is authorized to grant declaratory judgment under the Declaratory 
Judgment Act, 28 U.S.C. §§ 2201–02, implemented through Rule 57 of the Federal Rules of Civil 
Procedure, and is authorized to grant a temporary restraining order and injunctive relief pursuant 
to Rule 65 of the Federal Rules of Civil Procedure. 
23. 
This Court is authorized to grant Calvary Chapel’s prayer for relief regarding costs, 
including a reasonable attorney’s fee, pursuant to 42 U.S.C. § 1988. 
GENERAL ALLEGATIONS 
A. 
GOVERNOR MILLS’ EXECUTIVE ORDERS AND RELATED ORDERS 
FROM THE STATE OF MAINE. 
 
24. 
On March 15, 2020, in response to COVID-19, Governor Mills issued Proclamation 
of State of Civil Emergency to Further Protect Public Health, which declared a state of emergency 
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in the State of Maine. A true and correct copy of the March 15th Emergency Proclamation is 
attached hereto as EXHIBIT A and incorporated herein. 
25. 
In the Emergency Proclamation, Governor Mills stated that COVID-19 “poses an 
imminent threat of substantial harm to our citizens” and directed various government agencies to 
implement certain restrictions and orders to facilitate the State’s response. 
26. 
On March 18, 2020, Governor Mills issued Executive Order 14 stating that 
“[g]atherings of more than 10 people are prohibited throughout the State,” and declared that such 
a prohibition was primarily aimed at “social, personal, and discretionary events,” including those 
gatherings that are “faith-based.” A true and correct copy of Executive Order 14 is attached hereto 
as EXHIBIT B and incorporated herein. 
27. 
On March 24, 2020, Governor Mills issued Executive Order 19, which continued 
to prohibit all gatherings of more than 10 people. A true and correct copy of Executive Order 19 
is attached hereto as EXHIBIT C and incorporated herein. 
28. 
Though continuing the prohibition on “faith-based” gatherings (i.e., church) of 
more than 10 people, Governor Mills carved out a massive exemption from such prohibitions for 
businesses deemed “essential” and for certain businesses deemed “non-essential.” Such “essential 
businesses include inter alia “grocery and household goods” stores, gas stations, “home repair, 
hardware and auto repair” stores, and “convenience stores.” This exemption likewise permitted 
“big box” stores to continue operations. 
29. 
Businesses deemed “essential” are permitted to continue operations subject to the 
requirement—but only “to maximum extent practicable”—that they adhere to social distancing 
recommendations, maintaining a six-foot distance between individuals, and other measures 
recommended by various government agencies. 
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30. 
Executive Order 19 also permitted “non-essential” businesses to continue provided 
in-person contact with customers is restricted, they do not require more than 10 employees in a 
space where distancing is not possible, and are facilitated by remote employees to the maximum 
extent practicable. These non-essential businesses include “shopping malls, theaters, casinos . . .  
exercise gyms . . . massage facilities . . ., and other personal care and treatment facilities.” 
31. 
Violation of Executive Order 19 carried with it criminal and business licensing 
penalties. 
32. 
On March 31, 2020, Governor Mills issued Executive Order 28, which stated: “[a]ll 
persons living in the State of Maine are hereby ordered, effective as of 12:01 AM on April 2, 2020 
to stay at their homes or places of residence.” A true and correct copy of Executive Order 28 is 
attached hereto as EXHIBIT D and incorporated herein. 
33. 
Executive Order 28 only permitted residents to travel out of their homes if they 
were conducting “essential” activities or traveling to work at a business allowed to continue 
operations. 
34. 
Executive Order 28 further restricted the functions of “essential” businesses by 
setting numerical limitations on the number of customers or patrons depending on the square 
footage of the building in which the business was located, permitting 5 people for buildings of less 
than 7,500 square feet, 15 people for buildings between 7,500 and 25,000 square feet, 50 people 
for buildings between 25,000 and 50,000 square feet, 75 people for buildings between 50,000 and 
75,000 square feet, and 100 for buildings larger than 75,000 square feet. 
35. 
The exemption allowing “essential” businesses to operate subject to numerical 
limitations was not applicable to faith-based gatherings or churches, regardless of the size of the 
building in which such worship services take place. 
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36. 
Executive Order 28 stated that violations constituted a class E crime subject to up 
to six months in jail and a $1,000 fine. 
37. 
On April 3, 2020, Governor Mills issued a list further explaining what businesses 
were considered “essential” and those deemed “non-essential” under the previous Executive 
Orders. A true and correct copy of Governor Mills’ “Essential Business List” is attached hereto as 
EXHIBIT E and incorporated herein. 
38. 
The list of “essential” businesses included grocery stores, household goods stores, 
gas stations, hardware stores, home repair stores, garden centers and stores, child care services, 
and marijuana dispensaries. 
39. 
Executive Order 28 stated that its prohibitions were in effect until April 30, 2020. 
40. 
On April 14, 2020, Governor Mills issued a Proclamation to Renew the State of 
Civil Emergency in Maine, extending the purported authorities in Maine to continue to order 
prohibitions on religious gatherings and business closures for another 30 days. A true and correct 
copy of the Proclamation Extension is attached hereto as EXHIBIT F and incorporated herein. 
41. 
On April 29, 2020, Governor Mills issued Executive Order 49, further extending 
her stay-at-home orders until at least May 31. A true and correct copy of Executive Order 49 is 
attached hereto as EXHIBIT G and incorporated herein. 
42. 
Executive Order 49 explicitly states that all of the prohibitions concerning “faith-
based” gatherings remain in full effect, and that certain guidance documents would be made 
available concerning the potential re-opening of Maine’s economy in the coming days. 
43. 
Executive Order 49 states that the “Restarting Plan” would permit certain 
businesses and operations to reopen subject to the guidelines stated in the Restarting Plan, and that 
those businesses or activities allowed to open were “subject to change depending upon the 
demonstrated efficacy of the conditions imposed” on those businesses or activities. 
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44. 
On April 28, 2020, Governor Mills released the “Restarting Maine’s Economy” 
plan, further outlining the Governor’s continued prohibitions on certain gatherings. A true and 
correct copy of the Restarting Maine’s Economy plan is attached hereto as EXHIBIT H and 
incorporated herein. 
45. 
Restarting Maine’s Economy contemplates that businesses and activities will be 
permitted to reopen in phases with “Stage 1” contemplated to begin sometime in May, but the plan 
states that no concrete decisions have been made and that “decisions will be determined by public 
health metrics.” 
46. 
If Governor Mills does permit Stage 1 to commence sometime in May, although it 
is not certain based on the plan, certain functions at churches and “religious” gatherings will be 
permitted under Governor Mills’ proscribed orthodoxy for worship services 
47. 
Stage 1 contemplates “a continued prohibition on gathering of more than 10 
people.” 
48. 
Restarting Maine’s Economy states that churches or religious organizations, if 
permitted to open during Stage 1, will be “[l]imited to drive-in, stay-in-your-vehicle church 
services.” Otherwise, as contemplated in Executive Order 49, the stay-at-home order remains in 
full effect prohibiting any gathering of individuals. 
49. 
Churches and religious gatherings are not mentioned in any of the subsequent 
stages, and thus no further guidance on the speculative “drive-in stay-in-your-vehicle church 
services” potentially coming sometime in May will continue beyond May or whether different 
circumstances and prohibitions will continue. 
50. 
Calvary Chapel hereinafter refers to Executive Order 14, Executive Order 19, 
Executive Order 28, Executive Order 49, and the Restarting Maine’s Economy plan (EXHBITS 
A–H) collectively as the “GATHERING ORDERS.” 
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B. 
THE STATE’S ENFORCEMENT OF GOVERNOR MILLS’ GATHERING 
ORDERS. 
 
51. 
On April 2, 2020, the Maine State Police issued press statements indicating that it 
will enforce Governor Mills’ GATHERING ORDERS against churches and individuals found in 
violation of them. A true and correct copy of the Maine State Police’s Enforcement Practices 
Memorandum is attached hereto as EXHIBIT I and incorporated herein. 
52. 
The Enforcement Memorandum states that while the Maine State Police is “asking 
for voluntary compliance” with the GATHERING ORDERS, the State Police will—in certain 
circumstances—“issu[e] summonses or mak[e] physical arrests” for violating the GATHERING 
ORDERS. 
53. 
The Enforcement Memorandum explicitly notes that the Maine State Police will be 
“ask[ing] questions to ensure compliance” and that it hopes residents of Maine will “not put our 
officers in the position of having to enforce the law.” 
54. 
Through its Enforcement Memorandum, the Maine State Police has unquestionably 
demonstrated that it intends to enforce the GATHERING ORDERS, including against Calvary 
Chapel and its religious services. 
C. 
CALVARY CHAPEL’S CHURCH SERVICES CAN AND WILL COMPLY 
WITH 
SOCIAL 
DISTANCING 
AND 
PERSONAL 
HYGIENE 
RECOMMENDATIONS. 
 
55. 
To comply with the CDC and other governmental social distancing and personal 
hygiene guidelines imposed by Governor Mills’ GATHERING ORDERS (i.e., “to maximum 
extent practicable” for exempted businesses) for its worship services, Calvary Chapel can and 
would practice stringent social distancing and personal hygiene protocols, including extensive and 
enhanced sanitizing of common surfaces in Calvary Chapel’s building prior to the service, and 
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requiring attendees to remain at least six feet apart and use hand sanitizer prior to entering and 
during movement inside Calvary Chapel’s building. 
56. 
Calvary Chapel also has the capability to abide by all of the guidelines set out by 
the Maine Center for Disease Control and Prevention and will implement all such guidelines at its 
in-person religious gatherings. 
D. 
GOVERNOR MILLS’ UNEQUAL TREATMENT OF NON-RELIGIOUS 
GATHERINGS. 
 
57. 
On May 3, 2020, at around the same time as Calvary Chapel was prohibited from 
hosting its in-person religious worship services, businesses in Bangor and the surrounding area 
were permitted to and did continue to operate without the onerous restrictions imposed on Calvary 
Chapel. 
58. 
As accurately depicted in the below photographs, on May 3, 2020, around the same 
time that Calvary Chapel was prohibited from having a religious gathering, the Walmart in Bangor 
had hundreds of cars parked in the parking lot, right next to one another without the onerous social 
distancing mandates forced on Calvary Chapel. 
 
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59. 
Similarly, and as accurately depicted in the below photograph, on May 3, 2020, at 
the Target Store in Bangor, countless cars were present in the parking lot while Calvary Chapel 
was suffering under the yoke of the GATHERING ORDERS. 
 
60. 
As accurately depicted in the below photographs, on May 3, 2020, the Home Depot 
in Bangor was similarly permitted to continue operating with large numbers of people while 
Calvary Chapel was threatened with enforcement under the GATHERING ORDERS. 
 
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61. 
As accurately depicted in the below photograph, the BJ’s Wholesale Club similarly 
had large gatherings on May 3, 2020 without the restrictions imposed on Calvary Chapel’s 
religious services. 
 
62. 
As accurately depicted in the below photograph, the Sam’s Club in Bangor had 
similar large gatherings on May 3, 2020, while Calvary Chapel was not permitted to host its 
religious gatherings of a similar nature. 
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63. 
Finally, and as accurately depicted in the below photographs, Lowe’s Home 
Improvement Store’s parking lot was filled with cars on May 3, 2020, while Calvary Chapel was 
prohibited from having such gatherings for its religious services. 
 
 
 
 
 
 
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E. 
LESS 
RESTRICTIVE 
ALTERNATIVES 
ARE 
AVAILABLE 
TO 
GOVERNOR MILLS. 
 
64. 
Despite Governor Mills’ insistence that in-person religious gatherings of more than 
10 people cannot continue because they would spread COVID-19, the State has failed to consider 
other, substantially less restrictive alternatives to an absolute prohibition on “religious” gatherings. 
65. 
Like the State of Maine, the State of Florida has issued stay-at-home executive 
orders and required the closure of all so-called “non-essential” businesses without unnecessarily 
discriminating against religious gatherings. On April 1, 2020, Florida Governor Ron DeSantis 
issued Executive Order 20-91, which included “religious services conducted in churches, 
synagogues, and houses of worship” as essential activities permitted to continue subject to 
social distancing and personal hygiene guidelines. A true and correct copy of Florida Executive 
Order 20-91 is attached hereto as EXHIBIT J and incorporated herein. 
66. 
The State of Indiana has likewise issued stay-at-home executive orders and required 
the closure of all so-called “non-essential” businesses without unnecessarily discriminating against 
religious gatherings. Governor Eric. J. Holcomb’s Executive Order 20-08 declared that “[r]eligious 
facilities, entities and groups, and religious gatherings” are essential and may continue to operate 
provided they follow appropriate social distancing and personal hygiene practices. A true and 
correct copy of Indiana’s Executive Order 20-08 is attached hereto as EXHIBIT K and 
incorporated herein. 
67. 
The State of Arizona, in Executive Order 2020-18, classified “[e]ngaging in 
constitutionally protected activities such as speech and religion” as essential activities, subject to 
a flexible requirement that such engagement be “conducted in a manner that provides appropriate 
physical distancing to the extent feasible.” The Arizona Attorney General, in Opinion I20-008, 
interpreted such essential activities clearly to include assembling for religious worship. True and 
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correct copies of Arizona Executive Order 2020-18 and Arizona Attorney General Opinion 
I20-008 are attached hereto as EXHIBIT L and EXHIBIT M, respectively, and incorporated 
herein. 
68. 
The State of Alabama, in its final Order of the State Health Officer Suspending 
Certain Public Gatherings Due to Risk of Infection by COVID-19, issued April 3, 2020, exempts 
individuals attending religious worship services in person subject to certain requirements and 
permits “drive-in” worship services without limitation. A true and correct copy of the Alabama 
Order is attached hereto as EXHIBIT N and incorporated herein. 
69. 
The State of Arkansas has likewise exempted “places of worship” from its 
Executive Order 20-13 imposing restrictions to prevent the spread of COVID-19, provided that 
they engage in adequate social distancing and personal hygiene practices. A true and correct copy 
of the Arkansas Executive Order is attached hereto as EXHIBIT O and incorporated herein. 
70. 
The State of Connecticut has similarly shown that other, less restrictive alternatives 
are available. In Executive Order No. 7N, Governor Ned Lamont permitted religious services to 
continue to meet, but limited their in-person gatherings to 50 people, as opposed to the six-person 
limit applicable to other gatherings. A true and correct copy of the Connecticut Executive Order 
No. 7N is attached hereto as EXHIBIT P and incorporated herein. 
71. 
The State of Texas has likewise issued certain COVID-19 orders, but has provided 
explicit protections to religious gatherings and issued directives outlining the protection for 
religious freedom, even in these times of uncertainty. A true and correct copy of the Texas 
Guidance for Houses of Worship is attached hereto as EXHIBIT Q and incorporated herein. In 
that Guidance, Texas notes that religious assemblies and houses of worship are “essential services” 
and that in-person gatherings are permissible if social distancing and personal hygiene practices 
are followed. 
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72. 
The State of Ohio has likewise issued certain COVID-19 orders, including the Ohio 
Department of Health’s Stay Safe Ohio Order. A true and correct copy of the Ohio order is attached 
hereto as EXHIBIT R and incorporated herein. Ohio’s order likewise states that the stay at home 
mandate “does not apply to religious facilities, entities and groups and religious gatherings.” 
73. 
Numerous other states have similarly permitted religious gatherings to be treated 
equally with non-religious gatherings. 
74. 
As these other states have demonstrated, Governor Mills can continue to pursue the 
State’s objective of preventing the spread of COVID-19 without unnecessarily treating religious 
gatherings in a discriminatory manner, and the State has numerous other, less restrictive 
alternatives available to it to do so. 
75. 
Governor Mills has neither tried without success nor considered and ruled out 
for good reason these less restrictive alternatives. 
76. 
Governor Mills has constitutionally permissible alternatives available, but has 
failed to attempt to achieve the State’s purported goals without unnecessarily interfering with 
constitutionally protected activities. 
F. 
IRREPARABLE INJURY TO CALVARY CHAPEL FROM GOVERNOR 
MILLS’ GATHERING ORDERS. 
77. 
Despite being capable of following all social distancing and personal hygiene 
protocols recommended by the CDC and specified in the GATHERING ORDERS, Calvary Chapel 
has been explicitly targeted, singled out, and punished for participating in an in-person religious 
gathering when exempted commercial and non-religious entities may accommodate gatherings, 
crowds, and masses of people without numeric limitation, and without targeting or punishment by 
the government. 
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78. 
As a result of Governor Mills’ GATHERING ORDERS, Calvary Chapel has 
suffered and is suffering irreparable injury by having Pastor Graves and all attendees of future 
services threatened with criminal sanction. 
79. 
As a result of Governor Mills’ GATHERING ORDERS, Calvary Chapel has 
suffered and is suffering irreparable injury by being prohibited from engaging in its 
constitutionally and statutorily protected rights of free exercise, assembly, and speech. 
80. 
As a result of Governor Mills’ GATHERING ORDERS, Calvary Chapel has 
suffered and is suffering irreparable injury by the infringement of its constitutionally protected 
right to be free from government hostility toward religion. 
81. 
As a result of the Governor Mills’ GATHERING ORDERS and the explicit threats 
from the Maine State Police, Calvary Chapel has suffered and is suffering irreparable injury by the 
continuing threat of criminal sanctions against Calvary Chapel’s Pastor Graves and congregants 
for merely exercising their constitutionally protected freedoms. 
82. 
Due to the explicit threats of Governor Mills’ GATHERING ORDERS and the 
announcements by the Maine State Police, Calvary Chapel has been forced to self-censor, cease 
its religious worship services, and violate its sincerely held religious beliefs. 
G. 
CALVARY CHAPEL’S ATTEMPTS TO SECURE RELIEF WITHOUT 
JUDICIAL 
INTERVENTION 
WERE 
IGNORED 
AND 
FURTHER 
ATTEMPTS 
TO 
NOTIFY 
THE 
STATE 
ARE 
FUTILE 
AND 
IMPRACTICAL BEFORE THIS SUNDAY. 
83. 
On May 4, 2020, prior to the commencement of the instant action, Calvary Chapel’s 
counsel sent by email a demand letter to Governor Mills, with copies to state and local police and 
other officials, in which Calvary Chapel’s counsel demanded, by 5:00 P.M. on May 5, written 
confirmation that the State has withdrawn the ban on religious gatherings embodied in the 
GATHERING ORDERS, will allow individuals to attend church services at Calvary Chapel in an 
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equal manner with other essential and non-essential business permitted to continue provided 
certain social distancing and personal hygiene practices are followed, and will cease enforcement 
of any church gathering ban against members and/or attendees of Calvary Chapel church services. 
A true and correct copy of the demand letter is attached hereto as EXHIBIT S. No written response 
from Governor Mills’ office was received by the requested deadline, or at any time prior to the 
filing of this Verified Complaint. 
84. 
The failure of Governor Mills or her officials to confirm withdrawal or cessation of 
enforcement of the discriminatory gathering ban for religious services in the GATHERING 
ORDERS and applied to Calvary Chapel and its pastor shows that Calvary Chapel’s irreparable 
injury to its constitutionally protected freedoms is ongoing. 
85. 
The failure of Governor Mills or her officials to respond to Calvary Chapel’s 
communication also shows that notice and an opportunity to respond to this lawsuit cannot be 
effectuated, and would be futile, prior to this Sunday’s worship activities at Calvary Chapel, when 
the State and/or other government officials will again interfere with the constitutional liberties of 
Calvary Chapel and its congregants absent a temporary restraining order from this Court. 
CONSTITUTIONAL CLAIMS 
COUNT I—THE GATHERING ORDERS VIOLATE 
PLAINTIFF’S RIGHT TO FREE EXERCISE OF RELIGION 
UNDER THE FIRST AMENDMENT 
 
86. 
Calvary Chapel hereby realleges and adopts each and every allegation in paragraphs 
1–85 above. 
87. 
The Free Exercise Clause of the First Amendment to the United States Constitution, 
as applied to the states by the Fourteenth Amendment, prohibits the State from abridging Calvary 
Chapel’s rights to free exercise of religion. 
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88. 
Calvary Chapel has sincerely held religious beliefs that Scripture is the infallible, 
inerrant word of the Lord Jesus Christ, and that it is to follow its teachings. 
89. 
Calvary Chapel has sincerely held religious beliefs, rooted in Scripture’s 
commands (e.g., Hebrews 10:25), that followers of Jesus Christ are not to forsake the assembling 
of themselves together, and that they are to do so even more in times of peril and crisis. Indeed, 
the entire purpose of the Church (in Greek “ekklesia,” meaning “assembly”) is to assemble 
together Christians to worship Almighty God. 
90. 
The GATHERING ORDERS, on their face and as applied, target Calvary Chapel’s 
sincerely held religious beliefs by prohibiting religious gatherings. 
91. 
The GATHERING ORDERS, on their face and as applied, impermissibly burden 
Calvary Chapel’s sincerely held religious beliefs, compel Calvary Chapel to either change those 
beliefs or to act in contradiction to them, and force Calvary Chapel to choose between the teachings 
and requirements of its sincerely held religious beliefs in the commands of Scripture and the State’s 
imposed value system. 
92. 
The GATHERING ORDERS, on their face and as applied, place Calvary Chapel 
in an irresolvable conflict between compliance with the GATHERING ORDERS and its sincerely 
held religious beliefs. 
93. 
The GATHERING ORDERS, on their face and as applied, put substantial pressure 
on Calvary Chapel to violate its sincerely held religious beliefs by ignoring the fundamental 
teachings and tenets of Scripture concerning the assembling of Believers. 
94. 
The GATHERING ORDERS, on their face and as applied, are neither neutral nor 
generally applicable, but rather specifically and discriminatorily target the religious beliefs, 
speech, assembly, and viewpoint of Calvary Chapel. 
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95. 
The GATHERING ORDERS, on their face and as applied, constitute a substantial 
burden on Calvary Chapel’s sincerely held religious beliefs. 
96. 
The State lacks a compelling, legitimate, or rational interest in the GATHERING 
ORDERS’ application of different standards for churches and religious gatherings than those 
applicable to exempted businesses or non-religious entities. 
97. 
Even if the GATHERING ORDERS’ restriction on religious gatherings were 
supported by a compelling interest, which it is not, they are not the least restrictive means to 
accomplish the government’s purported interest. 
98. 
The GATHERING ORDERS, on their face and as applied, fail to accommodate 
Calvary Chapel’s sincerely held religious beliefs. 
99. 
The GATHERING ORDERS, on their face and as applied, specifically target 
Calvary Chapel’s sincerely held religious beliefs and set up a system of individualized exemptions 
that permits certain other similarly situated businesses or non-religious entities to continue 
operations under certain guidelines while prohibiting religious gatherings, such as Calvary 
Chapel’s church and worship services, from operating with similar guidelines. 
100. 
The GATHERING ORDERS, on their face and as applied, constitute an express 
and overt religious gerrymander. 
101. 
The GATHERING ORDERS, on their face and as applied, have caused, are 
causing, and will continue to cause Calvary Chapel immediate and irreparable harm, and actual 
and undue hardship. 
102. 
Calvary Chapel has no adequate remedy at law to correct the continuing deprivation 
of its most cherished liberties. 
WHEREFORE, Calvary Chapel respectfully prays for relief against the State as hereinafter 
set forth in its prayer for relief. 
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COUNT II—THE GATHERING ORDERS VIOLATE 
PLAINTIIFF’S RIGHT TO PEACEABLE ASSEMBLY 
UNDER THE FIRST AMENDMENT 
 
103. 
Calvary Chapel hereby realleges and adopts each and every allegation in paragraphs 
1–85 above. 
104. 
The First Amendment to the United States Constitution, as applied to the states by 
the Fourteenth Amendment, prohibits the State from abridging the right of the people peaceably 
to assemble. 
105. 
The GATHERING ORDERS, on their face and as applied, are an unconstitutional 
prior restraint on Calvary Chapel’s right to assemble. 
106. 
The GATHERING ORDERS, on their face and as applied, unconstitutionally 
discriminate on the basis of viewpoint. 
107. 
The GATHERING ORDERS, on their face and as applied, unconstitutionally 
discriminate on the basis of content. 
108. 
The State lacks a compelling, legitimate, or rational interest in the GATHERING 
ORDERS’ application of differential standards for churches and religious gatherings than those 
applicable to exempted businesses or non-religious entities. 
109. 
The GATHERING ORDERS, on their face and as applied, are not the least 
restrictive means to accomplish any permissible government purpose sought to be served by the 
orders. 
110. 
The GATHERING ORDERS, on their face and as applied, are not narrowly tailored 
to serve the government’s purported interest. 
111. 
The GATHERING ORDERS, on their face and as applied, do not leave open ample 
alternative channels of communication for Calvary Chapel. 
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112. 
The GATHERING ORDERS, on their face and as applied, are irrational and 
unreasonable and impose unjustifiable and unreasonable restrictions on Calvary Chapel’s 
constitutionally protected right to assemble. 
113. 
The GATHERING ORDERS, on their face and as applied, impermissibly vest 
unbridled discretion in the hands of government officials, including Governor Mills and her 
designees, to apply or not apply the GATHERING ORDERS in a manner to restrict free assembly. 
114. 
The GATHERING ORDERS, on their face and as applied, are underinclusive by 
limiting their gathering prohibitions to only certain businesses or organizations deemed “non-
essential.” 
115. 
The GATHERING ORDERS, on their face and as applied, are unconstitutionally 
vague and overbroad as they chill and abridge the free assembly rights of Calvary Chapel. 
116. 
On their face and as applied, the GATHERING ORDERS’ violation of Calvary 
Chapel’s right to free assembly have caused, are causing, and will continue to cause Calvary 
Chapel to suffer immediate and irreparable injury and undue and actual hardship. 
117. 
Calvary Chapel has no other adequate remedy at law to correct the continuing 
deprivation of its most cherished liberties. 
WHEREFORE, Calvary Chapel respectfully prays for the relief against the State as 
hereinafter set forth in its prayer for relief. 
COUNT III - THE GATHERING ORDERS VIOLATE 
PLAINTIFF’S RIGHTS TO FREEDOM OF SPEECH 
UNDER THE FIRST AMENDMENT 
 
118. 
Calvary Chapel hereby realleges and adopts each and every allegation in paragraphs 
1–85 above. 
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119. 
The Free Speech Clause of the First Amendment to the United States Constitution, 
as applied to the states by the Fourteenth Amendment, prohibits the State from abridging Calvary 
Chapel’s freedom of speech. 
120. 
The GATHERING ORDERS, on their face and as applied, are an unconstitutional 
prior restraint on Calvary Chapel’s speech. 
121. 
The GATHERING ORDERS, on their face and as applied, unconstitutionally 
discriminate on the basis of viewpoint. 
122. 
The GATHERING ORDERS, on their face and as applied, unconstitutionally 
discriminate on the basis of content. 
123. 
The State lacks a compelling, legitimate, or rational interest in the GATHERING 
ORDERS’ application of different standards for churches and religious gatherings than those 
applicable to exempted businesses and non-religious entities. 
124. 
The GATHERING ORDERS, on their face and as applied, are not the least 
restrictive means to accomplish any permissible government purpose sought to be served by the 
orders. 
125. 
The GATHERING ORDERS, on their face and as applied, are not narrowly tailored 
to serve the government’s purported interest. 
126. 
The GATHERING ORDERS, on their face and as applied, do not leave open ample 
alternative channels of communication for Calvary Chapel. 
127. 
The GATHERING ORDERS, on their face and as applied, are irrational and 
unreasonable and impose unjustifiable and unreasonable restrictions on Calvary Chapel’s 
constitutionally protected speech. 
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128. 
The GATHERING ORDERS, on their face and as applied, impermissibly vest 
unbridled discretion in the hands of government officials, including Governor Mills and her 
designees, to apply or not apply the GATHERING ORDERS in a manner to restrict free speech. 
129. 
The GATHERING ORDERS, on their face and as applied, are underinclusive by 
limiting their prohibitions to only certain entities, organizations, or businesses deemed “non-
essential.” 
130. 
The GATHERING ORDERS, on their face and as applied, are unconstitutionally 
overbroad as they chill and abridge the free speech rights of Calvary Chapel. 
131. 
On their face and as applied, the GATHERING ORDERS’ violation of Calvary 
Chapel’s rights to free speech have caused, are causing, and will continue to cause Calvary Chapel 
to suffer immediate and irreparable injury and undue and actual hardship. 
132. 
Calvary Chapel has no other adequate remedy at law to correct the continuing 
deprivation of its most cherished liberties. 
WHEREFORE, Calvary Chapel respectfully prays for the relief against the State as 
hereinafter set forth in its prayer for relief. 
COUNT IV—THE GATHERING ORDERS VIOLATE 
THE ESTABLISHMENT CLAUSE OF THE FIRST AMENDMENT 
133. 
Calvary Chapel hereby realleges and adopts each and every allegation in paragraphs 
1–85 above. 
134. 
The Establishment Clause of the First Amendment to the United States 
Constitution, as applied to the states by the Fourteenth Amendment, prohibits the government from 
establishing a religion. 
135. 
The Establishment Clause also prohibits excessive government entanglement with 
religion. 
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136. 
The Establishment Clause also prohibits the government from showing hostility 
towards religion and prohibits showing favoritism towards one religious sect over another or 
between non-religion and religion. 
137. 
The government mandated prohibition on “faith-based” gatherings in the 
GATHERING ORDERS violates the Establishment Clause because the State of Maine thereby 
dictates the manner in which Christians and churches must worship or worship online.  
138. 
The Establishment Clause does not permit the State of Maine to dictate under 
penalty of criminal sanctions the manner, style, form, practices, or sacraments of religious worship 
and thereby impose its own version of religious worship on every church and citizen of the State. 
139. 
In fact, as the Supreme Court has unequivocally stated, “[i]f there is any fixed star 
in our constitutional constellation, it is that no official, high or petty, can prescribe what shall be 
orthodox in politics, nationalism, religion, or other matters of opinion or force citizens to confess 
by word or act their faith therein.” W. Va. State Bd. of Educ. v. Barnette, 319 U.S. 624, 642 (1943) 
(emphasis added). 
140. 
The State, through Governor Mills’ GATHERING ORDERS, is purporting to 
prescribe what shall be orthodox in matters of religious worship, and is thus running roughshod 
over the Establishment Clause. 
141. 
The GATHERING ORDERS, on their face and as applied, permit the State to 
display impermissible hostility towards religious gatherings. 
142. 
The GATHERING ORDERS, on their face and as applied, impermissibly show 
favoritism towards certain non-religious gatherings over religious gatherings. 
143. 
The GATHERING ORDERS, on their face and as applied, violate the 
Establishment Clause because they excessively entangle the government with religion. 
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144. 
The GATHERING ORDERS, on their face and as applied, purport to inform 
religious adherents and believers how they may choose to worship, assemble together, or engage 
in their religious freedoms. 
145. 
The GATHERING ORDERS, on their face and as applied, purport to establish an 
acceptable method of religious practice and worship, place a numerical limitation on the scope of 
how such religious practice and worship may occur, and provide a government imprimatur for 
only certain forms of “permissible” worship. 
146. 
The GATHERING ORDERS, on their face and as applied, demonstrate overt 
hostility to religious practice and worship that does not conform to government sanctioned 
religious exercises. 
147. 
The GATHERING ORDERS, on their face and as applied, have caused, are 
causing, and will continue to cause Calvary Chapel immediate and irreparable harm, and actual 
and undue hardship. 
148. 
Calvary Chapel has no adequate remedy at law to correct the continuing deprivation 
of its most cherished constitutional liberties.  
WHEREFORE, Calvary Chapel respectfully prays for the relief against the State as 
hereinafter set forth in their prayer for relief. 
COUNT V—THE GATHERING ORDERS VIOLATE 
PLAINTIFF’S RIGHT TO EQUAL PROTECTION 
UNDER THE FOURTEENTH AMENDMENT 
 
149. 
Calvary Chapel hereby realleges and adopts each and every allegation in paragraphs 
1–85 above. 
150. 
The Fourteenth Amendment to the United States Constitution guarantees Calvary 
Chapel the right to equal protection under the law. 
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151. 
The GATHERING ORDERS, on their face and as applied, are an unconstitutional 
abridgement of Calvary Chapel’s right to equal protection under the law, are not neutral, and 
specifically target Calvary Chapel’s and other religious gatherings for unequal treatment. 
152. 
The GATHERING ORDERS, on their face and as applied, are an unconstitutional 
abridgment of Calvary Chapel’s right to equal protection because they permit the State to treat 
Calvary Chapel differently from other similarly situated businesses and non-religious entities on 
the basis of the content and viewpoint of Calvary Chapel’s gatherings. 
153. 
The GATHERING ORDERS create a system of exempt categories that permit 
essential businesses and gatherings to continue to operate with restriction or threat of sanction, and 
impose disparate treatment to those categories of businesses and gatherings called “non-essential.” 
154. 
The GATHERING ORDERS system of categories represents disparate treatment 
based upon classification in violation equal protection. 
155. 
The GATHERING ORDERS, on their face and as applied, impermissibly 
discriminate between certain non-religious gatherings and religious gatherings. 
156. 
The State lacks a compelling, legitimate, or rational interest in the GATHERING 
ORDERS’ application of different standards for churches and religious gatherings than those 
applicable to exempted businesses or non-religious entities. 
157. 
The GATHERING ORDERS, on their face and as applied, are not the least 
restrictive means to accomplish any permissible government purpose sought to be served. 
158. 
The GATHERING ORDERS, on their face and as applied, do not have a rational 
basis. 
159. 
The GATHERING ORDERS, on their face and as applied, are irrational and 
unjustifiable and impose irrational and unjustifiable restrictions on Calvary Chapel’s religious 
gatherings. 
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160. 
The GATHERING ORDERS, on their face and as applied, have caused, are 
causing, and will continue to cause Calvary Chapel immediate and irreparable harm, and actual 
and undue hardship. 
161. 
Calvary Chapel has no adequate remedy at law to correct the continuing deprivation 
of its most cherished liberties. 
WHEREFORE, Calvary Chapel respectfully prays for relief against the State as hereinafter 
set forth in its prayer for relief. 
COUNT VI—THE GATHERING ORDERS VIOLATE 
PLAINTIFF’S RIGHT TO A REPUBLICAN FORM OF GOVERNMENT 
UNDER THE GUARANTEE CLAUSE OF ARTICLE IV, § 4 OF 
THE UNITED STATES CONSTITUTION 
 
162. 
Calvary Chapel hereby realleges and adopts each and every allegation in paragraphs 
1–85 above. 
163. 
Article IV, § 4 of the United States Constitution requires the United States to 
guarantee to every citizen in the nation a republican form of government. 
164. 
The Guarantee Clause’s distinguishing feature is that the republican form of 
government it guarantees is the right of the people to choose their own governmental 
administration and pass their own laws. 
165. 
As interpreted by the federal judiciary and prominent scholars, the Guarantee 
Clause mandates that the federal government guarantee a form of government for all citizens in 
which supreme power resides in a body of citizens entitled to vote and exercised by elected officers 
responsible to such citizens. 
166. 
The GATHERING ORDERS’ express, unilateral, and unequivocal exercises of 
purported executive authority over the constitutional rights of Calvary Chapel deprive Calvary 
Chapel of the right to select its own government administration, pass its own laws, and maintain a 
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government administration directly responsible to the people, including by laws that are enacted 
by the legislature in constitutional recognition of the separation of powers. 
167. 
The impermissible exercise of exclusive and unaccountable executive authority 
violates the Guarantee Clause of the United States Constitution. 
168. 
The GATHERING ORDERS, on their face and as applied, have caused, are 
causing, and will continue to cause Calvary Chapel immediate and irreparable harm, and actual 
and undue hardship. 
169. 
Calvary Chapel has no adequate remedy at law to correct the continuing deprivation 
of its most cherished liberties. 
WHEREFORE, Calvary Chapel respectfully prays for the relief against the State as 
hereinafter set forth in its prayer for relief. 
COUNT VII—THE GATHERING ORDERS VIOLATE 
PLAINTIFF’S RIGHT TO FREE EXERCISE OF RELIGION UNDER 
ARTICLE I, SECTION 3 OF THE CONSTITUTION OF THE STATE OF MAINE 
 
170. 
Calvary Chapel hereby realleges and adopts each and every allegation in paragraphs 
1–85 above. 
171. 
Article I, § 3 of the Constitution of the State of Maine states: 
All individuals have a natural and unalienable right to worship Almighty God 
according to the dictates of their own consciences, and no person shall be hurt, 
molested or restrained in that person's liberty or estate for worshipping God in the 
manner and season most agreeable to the dictates of that person's own conscience, 
nor for that person's religious professions or sentiments, provided that that person 
does not disturb the public peace, nor obstruct others in their religious 
worship;—and all persons demeaning themselves peaceably, as good members of 
the State, shall be equally under the protection of the laws . . . . 
 
(Emphasis added.) 
172. 
Calvary Chapel has sincerely held religious beliefs that Scripture is the infallible, 
inerrant word of the Lord Jesus Christ, and that it is to follow its teachings. 
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173. 
Calvary Chapel has sincerely held religious beliefs, rooted in Scripture’s 
commands (e.g., Hebrews 10:25), that followers of Jesus Christ are not to forsake the assembling 
of themselves together, and that they are to do so even more in times of peril and crisis. Indeed, 
the entire purpose of the Church (in Greek “ekklesia,” meaning “assembly”) is to assemble 
together Christians to worship Almighty God. 
174. 
The GATHERING ORDERS, on their face and as applied, target Calvary Chapel’s 
sincerely held religious beliefs by prohibiting religious gatherings. 
175. 
The GATHERING ORDERS, on their face and as applied, impermissibly burden 
Calvary Chapel’s sincerely held religious beliefs, compel Calvary Chapel to either change those 
beliefs or to act in contradiction to them, and force Calvary Chapel to choose between the teachings 
and requirements of its sincerely held religious beliefs in the commands of Scripture and the State’s 
imposed value system. 
176. 
The GATHERING ORDERS, on their face and as applied, place Calvary Chapel 
in an irresolvable conflict between compliance with the GATHERING ORDERS and its sincerely 
held religious beliefs. 
177. 
The GATHERING ORDERS, on their face and as applied, put substantial pressure 
on Calvary Chapel to violate its sincerely held religious beliefs by ignoring the fundamental 
teachings and tenets of Scripture concerning the assembling of Believers. 
178. 
The GATHERING ORDERS, on their face and as applied, are neither neutral nor 
generally applicable, but rather specifically and discriminatorily target the religious beliefs, 
speech, assembly, and viewpoint of Calvary Chapel. 
179. 
The GATHERING ORDERS, on their face and as applied, constitute a substantial 
burden on Calvary Chapel’s sincerely held religious beliefs. 
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180. 
The State lacks a compelling, legitimate, or rational interest in the GATHERING 
ORDERS’ application of different standards for churches and religious gatherings than those 
applicable to exempted businesses or non-religious entities. 
181. 
Even if the GATHERING ORDERS’ restriction on religious gatherings were 
supported by a compelling interest, which it is not, they are not the least restrictive means to 
accomplish the government’s purported interest. 
182. 
The GATHERING ORDERS, on their face and as applied, fail to accommodate 
Calvary Chapel’s sincerely held religious beliefs. 
183. 
The GATHERING ORDERS, on their face and as applied, specifically target 
Calvary Chapel’s sincerely held religious beliefs and set up a system of individualized exemptions 
that permits certain other similarly situated businesses or non-religious entities to continue 
operations under certain guidelines while prohibiting religious gatherings, such as Calvary 
Chapel’s church and religious gatherings, from operating with similar guidelines. 
184. 
The GATHERING ORDERS, on their face and as applied, constitute an express 
and overt religious gerrymander. 
185. 
The GATHERING ORDERS, on their face and as applied, have caused, are 
causing, and will continue to cause Calvary Chapel immediate and irreparable harm, and actual 
and undue hardship. 
186. 
Calvary Chapel has no adequate remedy at law to correct the continuing deprivation 
of its most cherished liberties. 
WHEREFORE, Calvary Chapel respectfully prays for relief against the State as hereinafter 
set forth in its prayer for relief. 
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COUNT VIII—THE GATHERING ORDERS VIOLATE 
PLAINTIFF’S RIGHT TO FREEDOM OF SPEECH UNDER 
ARTICLE I, SECTION 4 OF THE CONSTITUTION OF THE STATE OF MAINE 
 
187. 
Calvary Chapel hereby realleges and adopts each and every allegation in paragraphs 
1–85 above. 
188. 
Article I, Section 4 of the Constitution of the State of Maine states that “[e]very 
citizen may freely speak, write and publish sentiments on any subject.” 
189. 
The GATHERING ORDERS, on their face and as applied, are an unconstitutional 
prior restraint on Calvary Chapel’s speech. 
190. 
The GATHERING ORDERS, on their face and as applied, unconstitutionally 
discriminate on the basis of viewpoint. 
191. 
The GATHERING ORDERS, on their face and as applied, unconstitutionally 
discriminate on the basis of content. 
192. 
The State lacks a compelling, legitimate, or rational interest in the GATHERING 
ORDERS’ application of different standards for churches and religious gatherings than those 
applicable to exempted businesses and non-religious entities. 
193. 
The GATHERING ORDERS, on their face and as applied, are not the least 
restrictive means to accomplish any permissible government purpose sought to be served by the 
orders. 
194. 
The GATHERING ORDERS, on their face and as applied, are not narrowly tailored 
to serve the government’s purported interest. 
195. 
The GATHERING ORDERS, on their face and as applied, do not leave open ample 
alternative channels of communication for Calvary Chapel. 
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196. 
The GATHERING ORDERS, on their face and as applied, are irrational and 
unreasonable and impose unjustifiable and unreasonable restrictions on Calvary Chapel’s 
constitutionally protected speech and right to assemble. 
197. 
The GATHERING ORDERS, on their face and as applied, impermissibly vest 
unbridled discretion in the hands of government officials, including Governor Mills and her 
designees, to apply or not apply the GATHERING ORDERS in a manner to restrict free speech 
and assembly. 
198. 
The GATHERING ORDERS, on their face and as applied, are underinclusive by 
limiting their prohibitions to only certain entities, organizations, or businesses deemed “non-
essential.” 
199. 
The GATHERING ORDERS, on their face and as applied, are unconstitutionally 
overbroad as they chill and abridge the free speech and assembly rights of Calvary Chapel. 
200. 
On their face and as applied, the GATHERING ORDERS’ violation of Calvary 
Chapel’s rights to free speech and assembly have caused, are causing, and will continue to cause 
Calvary Chapel to suffer immediate and irreparable injury and undue and actual hardship. 
201. 
Calvary Chapel has no other adequate remedy at law to correct the continuing 
deprivation of its most cherished liberties. 
WHEREFORE, Calvary Chapel respectfully prays for the relief against the State as 
hereinafter set forth in its prayer for relief. 
COUNT IX—THE GATHERING ORDERS VIOLATE 
PLAINTIFF’S RIGHT TO HAVE LAWS SUSPENDED 
ONLY BY THE MAINE LEGISLATURE 
 
202. 
Calvary Chapel hereby realleges and adopts each and every allegation in paragraphs 
1–85 above.  
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203. 
Article I, Section 13 of the Constitution of the State of Maine states that “[t]he laws 
shall not be suspended but by the Legislature or its authority.” 
204. 
The GATHERING ORDERS’ express, unilateral, and unequivocal exercise of 
purported executive authority over the constitutional rights of Calvary Chapel deprive Calvary 
Chapel of the right to select its own government administration, pass its own laws, and maintain a 
government administration directly responsible to the people, including by laws that are enacted 
by the legislature. 
205. 
The impermissible exercise of such executive authority violated the Constitution of 
Maine by purporting to suspend constitutional rights and laws of the State without legislative 
exercise of such suspension. 
206. 
The GATHERING ORDERS, on their face and as applied, have caused, are 
causing, and will continue to cause Calvary Chapel immediate and irreparable harm, and actual 
and undue hardship. 
207. 
Calvary Chapel has no adequate remedy at law to correct the continuing deprivation 
of its most cherished liberties. 
WHEREFORE, Calvary Chapel respectfully prays for the relief against the State as 
hereinafter set forth in its prayer for relief. 
STATUTORY CLAIMS 
COUNT X—THE GATHERING ORDERS VIOLATE PLAINTIFF’S RIGHTS UNDER  
THE RELIGIOUS LAND USE AND INSTITUTIONALIZED PERSONS ACT 
 
208. 
Calvary Chapel hereby realleges and adopts each and every allegation in paragraphs 
1–85 above. 
209. 
The Religious Land Use and Institutionalized Persons Act, 42 U.S.C. §§ 2000cc–
2000cc-5 (“RLUIPA”), states that “[n]o government shall impose or implement a land use 
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regulation in a manner that imposes a substantial burden on the religious exercise of a person, 
including a religious assembly or institution.” 42 U.S.C. § 2000cc(a)(1). If the government does 
impose such a restriction, it must then demonstrate that such a burden on the religious assembly is 
supported by a compelling interest and is the least restrictive means to further that alleged interest. 
210. 
RLUIPA further mandates that no government “impose or implement a land use 
regulation in a manner that treats a religious assembly or institution on less than equal terms with 
a nonreligious assembly or institution.” 42 U.S.C. § 2000cc(b)(1). 
211. 
RLUIPA further states that “[n]o government shall impose or implement a land use 
regulation that (A) totally excludes religious assemblies from a jurisdiction; or (B) unreasonably 
limits religious assemblies, institutions, or structures within a jurisdiction.” 42 U.S.C. 
§ 2000cc(b)(3). 
212. 
Calvary Chapel has sincerely held religious beliefs that Scripture is the infallible, 
inerrant word of the Lord Jesus Christ, and that Calvary Chapel is to follow its teachings. 
213. 
Calvary Chapel has sincerely held religious beliefs, rooted in Scripture’s 
commands (e.g., Hebrews 10:25), that followers of Jesus Christ are not to forsake the assembling 
of themselves together, and that they are to do so even more in times of peril and crisis. Indeed, 
the entire purpose of the Church (in Greek “ekklesia,” meaning “assembly”) is to assemble 
together Christians to worship Almighty God. 
214. 
The GATHERING ORDERS, on their face and as applied, target Calvary Chapel’s 
sincerely held religious beliefs by prohibiting religious gatherings. 
215. 
The GATHERING ORDERS, on their face and as applied, impermissibly and 
substantially burden Calvary Chapel’s sincerely held religious beliefs, compel Calvary Chapel to 
either change those beliefs or to act in contradiction to them, and force Calvary Chapel to choose 
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between the teachings and requirements of its sincerely held religious beliefs in the commands of 
Scripture and the State’s imposed value system. 
216. 
The GATHERING ORDERS, on their face and as applied, constitute a substantial 
burden on Calvary Chapel’s sincerely held religious beliefs. 
217. 
The State lacks a compelling interest in the GATHERING ORDERS’ application 
of different standards for churches and religious gatherings than those applicable to exempted 
businesses and non-religious entities. 
218. 
Even if the GATHERING ORDERS’ restrictions on religious gatherings was 
supported by a compelling interest, which it is not, they are not the least restrictive means to 
accomplish the government’s purported interest. 
219. 
The GATHERING ORDERS, on their face and as applied, have caused, are 
causing, and will continue to cause Calvary Chapel immediate and irreparable harm, and actual 
and undue hardship. 
220. 
Calvary Chapel has no adequate remedy at law to correct the continuing deprivation 
of its most cherished liberties. 
WHEREFORE, Calvary Chapel respectfully prays for relief against the State as hereinafter 
set forth in its prayer for relief. 
PRAYER FOR RELIEF 
 
WHEREFORE, Calvary Chapel prays for relief as follows: 
A. 
That the Court issue a Temporary Restraining Order restraining and enjoining 
Governor Mills, all State officers, agents, employees, and attorneys, and all other persons in active 
concert or participation with them, from enforcing, attempting to enforce, threatening to enforce, 
or otherwise requiring compliance with the GATHERING ORDERS or any other order to the 
extent any such order prohibits religious worship services at Calvary Chapel, or in-person church 
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41 
services at Calvary Chapel if Calvary Chapel meets the social distancing, enhanced sanitization, 
and personal hygiene guidelines pursuant to which the State allows so-called “essential” 
commercial and non-religious entities (e.g., beer, wine, and liquor stores, warehouse clubs, ‘big 
box’ and ‘supercenter’ stores, and marijuana dispensaries) to accommodate gatherings of persons 
without numerical limit. To be clear, Calvary Chapel merely seeks a TRO preventing Calvary 
Chapel, its pastor, and its members from being subject to criminal sanctions for hosting an 
in-person worship service on Sunday during which Calvary Chapel will implement social 
distancing and hygiene protections on an equal basis with other non-religious gatherings. In 
making such a request, Calvary Chapel merely seeks to be treated equally with other businesses, 
and seeks only to be permitted to meet in person so long as they abide by social distancing, 
enhanced sanitizing, and personal hygiene recommendations that other businesses are allowed to 
follow and remain open. 
B. 
That the Court issue a Preliminary Injunction pending trial, and a Permanent 
Injunction upon judgment, restraining and enjoining Governor Mills, all State officers, agents, 
employees, and attorneys, and all other persons in active concert or participation with them, from 
enforcing the GATHERING ORDERS so that: 
i. 
The State will not apply the GATHERING ORDERS in any manner as to 
infringe Calvary Chapel’s constitutional and statutory rights by 
discriminating against their right to assembly, speech, free exercise of 
religion, equal protection, and all other constitutional and statutory rights 
outlined herein; 
ii. 
The State will apply the GATHERING ORDERS in a manner that treats 
Calvary Chapel’s religious gatherings on equal terms as gatherings for or in 
so-called “essential” businesses and non-religious entities;  
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iii. 
The State will permit religious gatherings so long as they comply with the 
same social distancing and personal hygiene recommendations pursuant to 
which the State allows so-called “essential” commercial and non-religious 
entities (e.g., beer, wine, and liquor stores, warehouse clubs, and 
supercenters) to accommodate gatherings of persons without numerical 
limit under the GATHERING ORDERS; 
iv. 
The State will permit Calvary Chapel the opportunity to comport their 
behavior to any further limitations or restrictions that the State may impose 
in any future modification, revision, or amendment of the GATHERING 
ORDERS or similar legal directive; 
v. 
The State will cease issuing notices of criminal violation to Calvary 
Chapel’s Pastor, members, and/or attendees; and  
vii. 
The State will not bring any further enforcement, criminal, or other public 
health actions against Calvary Chapel as threatened in Governor Mills’ 
public statements. 
C. 
That the Court render a Declaratory Judgment declaring that the GATHERING 
ORDERS both on their face and as applied by the State are unconstitutional under the United 
States Constitution and Constitution of Maine, and further declaring that: 
i. 
The State has violated Calvary Chapel’s rights to freedom of assembly by 
impermissibly prohibiting religious gatherings; 
ii. 
The State has violated Calvary Chapel’s rights to freedom of speech by 
impermissibly prohibiting religious gatherings; 
iii. 
The State has violated Calvary Chapel’s rights to free exercise of religion 
by impermissibly prohibiting religious gatherings, substantially burdening 
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43 
their sincerely held religious beliefs, applying criteria that are neither 
neutral nor generally applicable to religious and non-religious gatherings, 
by establishing a religious gerrymander against religious gatherings, and by 
establishing a system of individualized exemptions that exclude similarly 
situated non-religious gatherings from the prohibitions applicable to 
Calvary Chapel’s religious gatherings; 
iv. 
The State has violated Calvary Chapels’ rights to equal protection of the 
laws by impermissibly prohibiting religious gatherings, and by applying 
criteria that treats religious gatherings in a discriminatory and dissimilar 
manner as that applied to various non-religious gatherings; 
v. 
The State has violated the Establishment Clause by impermissibly 
demonstrating hostility towards religious gatherings and by impermissibly 
showing favoritism to certain non-religious gatherings; 
vi. 
The State has violated the Guarantee Clause by impermissibly exercising 
executive authority in an unconstitutional manner; and 
vii. 
The State has violated the Religious Land Use and Institutionalized Persons 
Act by substantially and impermissibly burdening Calvary Chapel’s 
sincerely held religious beliefs and treating unequally as compared to other 
non-religious assemblies or institutions, by imposing draconian 
prohibitions on Calvary Chapel’s sincerely held religious beliefs without a 
compelling government interest, and without deploying the least restrictive 
means to achieve any permissible government interest. 
 
D. 
That the Court award Calvary Chapel nominal damages for the violation of Calvary 
Chapel’s constitutional rights. 
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E. 
That the Court adjudge, decree, and declare the rights and other legal relations 
within the subject matter here in controversy so that such declaration shall have the full force and 
effect of final judgment. 
 
F. 
That the Court retain jurisdiction over the matter for the purposes of enforcing the 
Court’s order. 
 
G. 
That the Court declare Calvary Chapel is prevailing parties and award Calvary 
Chapel the reasonable costs and expenses of this action, including a reasonable attorney’s fee, in 
accordance with 42 U.S.C. § 1988. 
H. 
That the Court grant such other and further relief as the Court deems equitable and 
just under the circumstances. 
 
 
 
Respectfully submitted, 
 
/s/ Charles W. Hodson 
 
/s/ Daniel J. Schmid  
 
Charles W. Hodson, II 
 
Mathew D. Staver* 
Charles W. Hodson, II Law Office 
Horatio G. Mihet* 
P.O. Box 1006 
 
 
Roger K. Gannam* 
Phone: (207) 945-3355 
 
Daniel J. Schmid* 
Facsimile: (207) 945-5104 
 
LIBERTY COUNSEL 
 
Email: cwh@hodsonlaw.com  
P.O. Box 540774 
 
 
 
 
 
 
Orlando, FL 32854 
Phone: (407) 875-1776 
 
 
 
 
 
 
Facsimile: (407) 875-0770 
 
 
 
 
 
 
Email: court@lc.org 
 
 
 
 
 
 
hmihet@lc.org 
 
 
 
 
 
 
rgannam@lc.org 
 
 
 
 
 
 
dschmid@lc.org 
 
 
 
 
 
 
 
*Pro hac vice applications pending 
 
 
 
 
 
 
Attorneys for Calvary Chapel of Bangor 
 
 
 
 
 
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VERIFICATION 
 
I, Kenneth Graves, am over the age of eighteen years and the Pastor of Calvary Chapel of 
Bangor, the Plaintiff in this action. The statements and allegations that pertain to me and/or 
Plaintiff Calvary Chapel of Bangor or which I make in this VERIFIED COMPLAINT are true and 
correct, and based upon my personal knowledge (unless otherwise indicated). If called upon to 
testify to their truthfulness, I would and could do so competently. I declare under penalty of 
perjury, under the laws of the United States and the State of Maine, that the foregoing statements 
are true and correct to the best of my knowledge. 
Dated: May 5, 2020 
 
 
 
 
 
/s/ Kenneth Graves 
 
 
 
 
 
 
 
Kenneth Graves 
Case 1:20-cv-00156-NT   Document 1   Filed 05/05/20   Page 45 of 45    PageID #: 45

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