“Personhood Without Piety” – The Third Circuit Affirms RFRA and Free-Exercise Protection for Non-Religious Entities in United States v. Safehouse

Introduction

United States v. Safehouse, No. 24-2027 (3d Cir. July 24, 2025), is the Second Circuit encounter with Safehouse’s proposed “overdose prevention site” in Philadelphia. After an earlier panel held that Safehouse’s supervised-use model violates 21 U.S.C. § 856(a)(2) (“the crack-house statute”), the non-profit returned to the district court asserting religious-freedom defenses. The district court dismissed those defenses, reasoning that a self-described “non-religious” corporation cannot invoke the Religious Freedom Restoration Act (RFRA) or the Free Exercise Clause. The Third Circuit—speaking through Judge Porter—reversed, holding that:

RFRA’s and the First Amendment’s protections extend to all “persons,” including corporations that do not label themselves as religious.

The opinion remands for analysis of Safehouse’s substantive claims and dismisses co-defendant José Benitez for lack of appellate standing, but its principal legacy is the doctrinal clarification that personhood, not piety, is the touchstone for statutory and constitutional religious-freedom guarantees.

Summary of the Judgment

Holding. The term “person” in RFRA (and the First Amendment’s corporate doctrine) unambiguously includes nonprofit corporations whether or not they are organized for an explicitly religious purpose.
Outcome. District court’s dismissal of Safehouse’s RFRA and Free Exercise counterclaims reversed; case remanded to decide whether Safehouse plausibly alleges a substantial burden and, if so, whether strict scrutiny is satisfied. Appeal as to Benitez dismissed.
Key Rationale. Reliance on the Dictionary Act, Burwell v. Hobby Lobby, and long-standing corporate constitutional rights; rejection of legislative-history-based limits proposed by DOJ.

Analysis

Precedents Cited and Their Influence

Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (2014) – Cornerstone for corporate RFRA rights. The Third Circuit borrows Hobby Lobby’s reasoning that the Dictionary Act’s definition of “person” controls unless displaced, and stresses the unanimous recognition that non-profit corporations are RFRA “persons.”
Bostock v. Clayton County, 590 U.S. 644 (2020) – Quoted for the principle that statutory breadth is not defeated because Congress failed to name every application in the legislative history.
Citizens United v. FEC, 558 U.S. 310 (2010) & other corporate-rights cases (Metro. Life v. Ward, Marshall v. Barlow’s) – Support the notion that corporations routinely exercise constitutional rights.
Masterpiece Cakeshop, Ltd. v. Colorado C.R. Comm’n, 584 U.S. 617 (2018) – Cited to show Free-Exercise protection for a profit-making entity.
United States v. Safehouse (“Safehouse I”), 985 F.3d 225 (3d Cir. 2021) – Earlier decision confirming that Safehouse’s site violates § 856(a)(2); demonstrates the panel’s adherence to plain-text methods—an interpretive theme carried forward here.

Legal Reasoning

Plain Text & Dictionary Act Control. RFRA bars substantial burdens on any “person’s” religious exercise. Under 1 U.S.C. § 1, “person” embraces “corporations, companies, associations… as well as individuals.” Nothing in RFRA alters that baseline.
Legislative History is Irrelevant When the Text is Clear. The court cites its own statement in Safehouse I—“when the text is clear, we will not look beyond it.” Reports saying nothing about non-religious entities cannot narrow the statute.
No “Religious-Purpose” Predicate. DOJ’s proposed requirement that corporate documents expressly bind an entity to religious principles has “no basis in RFRA’s text.” The object is the exercise of religion, not the entity’s charter language.
Free-Exercise Extension Mirrors RFRA Analysis. Corporate personhood under the First Amendment is “well established.” Free-exercise doctrine contains no carve-out for “non-religious” corporations; protecting the entity is a means of protecting the natural persons who act through it.
Standing & Procedural Holdings. Benitez lacked appellate standing because he asserted RFRA only as an affirmative defense, not a counterclaim. The panel declines to address Safehouse’s alternative request to amend because reversal moots the issue.

Potential Impact

Broader RFRA Coverage. The decision forecloses government arguments—popular since Hobby Lobby—that only “religious organizations” qualify. Expect non-traditional or mission-driven nonprofits (e.g., shelters, harm-reduction centers, secular pro-life or pro-choice groups) to cite this case.
New Litigation Trajectory for Safe Injection Sites. Although the court did not decide whether Safehouse ultimately wins on the merits, it kept the RFRA door open. The federal government must now justify § 856 enforcement under strict scrutiny or accommodate Safehouse’s practice.
Refined Religious-Exercise Inquiry. The remand forces lower courts to grapple with sincerity, “substantial burden,” and less-restrictive-means analysis in a public-health setting—terrain largely unexplored since the COVID-19 worship-restriction cases.
Separation-of-Powers Significance. By anchoring its holding in plain text, the Third Circuit reinforces a textualist interpretive approach, warning agencies not to rely on policy arguments or legislative silence.

Complex Concepts Simplified

RFRA. A 1993 federal statute restoring the strict-scrutiny test for laws that “substantially burden” religious exercise. Government must show a “compelling interest” implemented by the “least restrictive means.”
Free Exercise Clause. Part of the First Amendment prohibiting government interference with religious practice.
Dictionary Act (1 U.S.C. § 1). A short statute providing default definitions for words—like “person”—used across all federal laws.
Substantial Burden. A legal hurdle in RFRA litigation; government action “substantially burdens” religion when it pressures a claimant to modify or abandon a sincere religious practice.
Strict Scrutiny. Highest level of judicial review: the law must serve a compelling governmental interest and be narrowly tailored (least restrictive means) to achieve that interest.
Corporate Personhood. The legal fiction that a corporation is an independent “person” for purposes of owning property, suing, and asserting constitutional rights.
Harm Reduction. Public-health strategies aimed at minimizing the negative consequences of risky behavior (e.g., needle-exchange programs), rather than prohibiting the behavior outright.

Conclusion

United States v. Safehouse sets an important, perhaps sweeping, precedent: Neither RFRA nor the Free Exercise Clause requires an organization’s charter to proclaim religiosity before that organization may invoke religious-freedom protections. By focusing on statutory text and corporate personhood, the Third Circuit disavows legislative-history arguments that might leave secular-mission groups unprotected. On remand, the district court must confront the harder question—whether applying § 856(a)(2) to Safehouse can survive strict scrutiny. Irrespective of that ultimate outcome, the decision is poised to influence religious-freedom jurisprudence well beyond the supervised-injection context, ensuring that “persons” means what Congress said it means.