Judge Diarmuid O’Scannlain, the dissenting judge in the 2-1 decision, sided with Harvest Rock Church, stating: “There is no doubt that California’s COVID-19 scheme … imposes direct and severe burdens on religious practice within the State … Because California’s COVID-19 regulations patently disfavor religious practice when compared to analogous secular activities, I believe that the church is quite likely indeed to succeed on the merits of its challenge to such regulations.”