@Greytdog: No. At least as far as my experiences with making final arrangements for people goes, nobody can just walk in and start digging graves, planting stuff, installing monuments, etc. without the permission of the cemetery owners, which in many cases are the churches' properties. There are some state laws the cemeteries must follow in re: internment, and if people just come in willy-nilly and bury people in violation(s) thereof, the churches would be on the hook legally.