In United States v. Safehouse, (3d Cir., July 24, 2025), the U.S. 3rd Circuit Court of Appeals held that the Religious Freedom Restoration Act and the 1st Amendment’s Free Exercise clause apply to corporate entities, and to non-religious entities exercising religion. The United States contended that defendant’s offering of supervised illegal drug use violates federal law. Defendant argued that its overdose prevention services reflect its Board members’ religious belief in the value of human life. The court said in part:
RFRA’s plain text and Free Exercise doctrine are clear that those statutory and constitutional protections extend to non-natural persons, including so-called non-religious entities. In so holding, we express no view about whether threatened prosecution of Safehouse substantially burdens its exercise of religion. We likewise decline Safehouse’s invitation to determine in the first instance whether it has plausibly stated RFRA and Free Exercise claims. We only address the proper object of RFRA’s and the First Amendment’s protections: that object includes a non-natural entity allegedly exercising religion, even if the entity itself is not religious.