On Friday, November 13, 2020, just one day after California reported one million COVID-19 cases, Governor Gavin Newsom issued a travel advisory in an effort to discourage travel that could increase the spread of COVID-19. The advisory encourages Californians to avoid nonessential out-of-state travel and to stay home or “in their region” if possible. While “region” is not defined in the advisory, state health officials have discouraged travel between counties in different tiers of the state’s Blueprint. The advisory also calls on anyone arriving from another state or country to self-quarantine for 14 days after arrival.

Governor Newsom issued the advisory in conjunction with the governors of Oregon and Washington, and noted that case rates are rising in all three states and that “COVID-19 does not stop at state lines.” As of Friday, November 13, Oregon had also put in place the most stringent partial lockdown measure in the country, closing gyms and restaurants and limiting in-person gatherings to no more than six people.

This new travel advisory is not mandatory, just as other advisories issued by Governor Newsom have called on individuals to restrict their behavior to reduce the incidence of avoidable spread of the virus. The breadth of the Governor’s legal authority to restrict personal behavior in an effort to combat community spread of COVID-19 remains undefined. However, a California court in Sutter County recently struck down the Governor’s executive order on the conduct of state elections, holding that the Governor’s authority to issue emergency regulations due to the COVID-19 pandemic is not unlimited.