“Allowing drive-in church services involving congregants sitting in vehicles whose windows are closed represents the practical middle ground upon which concerns about religious freedom and the safety of the community may co-exist,” a district court ruled in the case of First Pentecostal Church of Holly Springs v. City of Holly Springs, Mississippi. “At the same time, this court wishes to be clear that it does not regard the practice of ‘drive-in’ church services as being risk-free.”