Jeff Goldstein, who described himself as a “semi-active pagan-Jewish minister,” got into trouble with the city of Madison, Wisconsin because he refused to mow his lawn, claiming that to do so would violate his deeply-held, religious belief that plants were sacred. He further explained that he prayed to his lawn, and that to mow it would be a “holocaust against the green creatures.” However, the court ruled that Goldstein had to mow his lawn anyway because he hadn't proved he was a follower of a genuine religion.