The most comparable previous effort was in 2008, when Carlos Bebeacua, a Uruguayan artist living in Sweden, attempted to register the Church of the Madonna of the Orgasm. The Kammarkollegiet refused his application, and in 2010 the Administrative Court of Appeal
upheld the rejection, arguing that the “madonna” (but not the “orgasm”) part of the church’s name would “cause offense not only in the broad groups of the population that have Christian roots, but also in society as a whole.”