 The Lutheran process, though rarely used, has created unusual situations in recent years due to its somewhat democratic excommunication process.One example was an effort to get serial killer Dennis Rader excommunicated from his denomination (the Evangelical Lutheran Church in America) by individuals who tried to "lobby" Rader's fellow church members into voting for his excommunication.The Church of England does not have any specific canons regarding how or why a member can be excommunicated, although it has a canon according to which ecclesiastical burial may be refused to someone "declared excommunicate for some grievous and notorious crime and no man to testify to his repentance".