Nowlin v. Pritzker

Plaintiffs lacked Article III standing to pursue their claims, alleging that defendant-Governor issued series of COVID-19-related executive orders that required Illinois citizens to shelter in place at their residences, compelled non-essential businesses to temporarily cease or reduce their operations and prohibited gatherings of more than 10 people, which, according to plaintiffs, violated their First Amendment rights, as well as their due process and equal protection rights and violated 5th Amendment Takings Clause. Plaintiffs failed to allege type of concrete and particularized injuries required to establish standing, where plaintiffs only made vague allegations such as being subjected to “severe restrictions on their religious liberty,” as well as restrictions on their right to freedom of speech and to peaceable assembly that did not contain any allegation that was specific to particular plaintiff or that described concrete harm. Moreover, while business plaintiffs had standing to pursue Takings Clause claim, where said plaintiffs alleged financial harm arising out of defendant’s executive orders, said plaintiffs failed to allege viable Takings Clause claim, where plaintiffs failed to allege specific facts that showed that defendant’s orders deprived them of all or significant part of their economically beneficial use of their properties.