Annual disputes over erecting displays celebrating the birth of Jesus on public land continue to pit some residents against advocacy groups pushing separation of church and state.
But some communities that put up the Nativity scenes on public property are rejecting demands for them to be removed.
The historic Hispanic city of Belen, New Mexico has repeatedly insisted it will keep up its year-round Nativity scene despite threats of legal action from the Wisconsin-based Freedom From Religion Foundation.
City councilors in Franklin, Pennsylvania voted last month to maintain its decades-old Nativity scene in a city park following a lawsuit threat.
The Florida-based Liberty Counsel that offers legal advice to cities that want to protect religious displays says municipalities are digging in to defend the displays.
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