In Steelmantown Church v. Carlton County, Minnesota, (D MN, March 11, 2026), a Minnesota federal district court dismissed claims under the Free Exercise and Establishment clauses, RLUIPA, and Minnesota law brought by a nonprofit corporation that was refused permission to establish a cemetery that would perform "green burials." While Minnesota law allowed "religious corporations" to establish private cemeteries, Steelmantown was not formed as a Minnesota religious corporation. The court, explaining its rejection of Steelmantown's 1stAmendment claims, said in part:
... [E]stablishing and operating a cemetery of any sort is not inherently or exclusively a religious practice, and Section 307.01 on its face does not “aid or oppose particular religions” or “establish[] a denominational preference.”... The statute expressly authorizes “any private person” or “any religious corporation,” regardless of whether they adhere to any religious faith, to establish a private cemetery on land the person or corporation owns.... The statute’s reference to “any religious corporation,” meaning those incorporated under Chapter 315, establishes only a preference toward a specific type of incorporated entity, not a particular religious faith or denomination....
Steelmantown effectively seeks preferential treatment because of its religious beliefs that a secular but otherwise identical institution—that is, a foreign nonprofit corporation whose “identity and mission” are not “derived from religious or spiritual traditions,” ... would not receive in the same circumstances. If anything, that outcome would appear to be closer to a violation of the Establishment Clause than the conduct Steelmantown challenges here....
Steelmantown’s claim, in essence, appears to be that its religious practices are burdened by the requirement to incorporate (or reincorporate) under Chapter 315.... But nowhere does Steelmantown allege any facts that show this requirement “significantly inhibit[s] or constrain[s]” any “conduct or expression that manifests some central tenet” of its religious beliefs, “meaningfully curtail[s]” its “ability to express adherence” to those beliefs, or denies it a “reasonable opportunity to engage in those activities.” ... It does not explain, for instance, why maintaining its status as a foreign nonprofit corporation under Chapter 303 is central to its ability to express its religious beliefs or engage in its religious practices. Nor does Steelmantown allege facts that suggest the requirement “operates so as to make the practice of [its] religious beliefs more expensive.”...
