Religious worship is fundamentally rooted in physical and intimate interactions. For instance, the Bible calls on Christian congregations to physically gather, receive the Lord’s Supper, sing praises, and confess their sins directly before ordained ministers. However, as the highly contagious and airborne COVID-19 disease relentlessly swept across the nation, religious establishments balanced fundamental religious traditions with the inherent dangers of carrying out such traditions. Inevitably, the free exercise of religion faces an unprecedented challenge as governors continue to enact executive orders limiting in-person religious worship gatherings. The jurisprudence thus far has shown alarming inconsistency in the protection of free exercise of religion, and this Note calls on the U.S. Supreme Court to provide clearer guidance for lower courts. Importantly, this Note argues that freedoms explicitly enumerated in the Bill of Rights nevertheless deserve the highest level of protection when infringed or burdened.