The least restrictive means would also include practical considerations like enforceability as well as the government being seen as giving deference to some gatherings versus others. It would be highly impractical for the police to be deployed to houses of worship to ensure that the members of the congregation are maintaining adequate social distancing and/or are all wearing appropriate masks. Furthermore, the non-religious may protest that the government is favoring religious practices i.e. attending church over secular practices such as going to a movie.