Depends if the pastor offered no other options but in person services and people ended up dying and it could be tracked back to the church ( hard to prove) then an argument may could be made that such a pastor deserved to be convicted of say involuntary manslaughter ( which here in GA for example carries between one year and one decade in the state pen (on a single charge) If the pastor did offer other options such as online or like our church has where you can listen in the parking lot at service time or wait a week and listen online then such a pastor could say I gave other options, so that charge may be even harder to stick. It would be hard to prove though that the person got the virus from attending the service, so it would be hard to get a conviction anyway.