In Wallace v. ConAgra Foods, Inc., No. 12-1354 (D. Minn. Jan. 31, 2013), the District Court of Minnesota granted defendant’s motion to dismiss plaintiffs’ lawsuit alleging that defendant misrepresented certain of its meat products as being kosher. Plaintiffs alleged that defendant, working through its contractor, Triangle K, an organization responsible for supervising the kosher processing activities at beef processing facilities, obtained false certifications that the meat was slaughtered in compliance with kosher requirements. The court dismissed the case, noting in part that plaintiff had not sued Triangle K, which actually did the certifying. Further, the court held that the determination of whether defendant’s products in fact satisfy kosher requirements is intrinsically religious in nature and that, as a consequence, the First Amendment bars courts from passing judgment concerning the adequacy or propriety of such determinations.