There is another way to look at this that might make this whole issue easier to understand. The issue is not the fact that the material is "religious," the issue is that your friend is not only trespassing on other people's private property, but also littering. It is all a matter of littering and that is illegal in most places.
Another way I have seen neighborhoods band together to stop this type of activity is to call the police when it happens and report that someone has left "pornographic material" on their property. If several neighbors get together and claim they personally believe religious material is pornographic (according to the Bible, the angel did rape Mary) , the police actually have to take it seriously because the definition of "pornography" in any given location is based on a "community standard."
I'll bet your friend would be truly surprised if he or she was out littering peoples' property and was suddenly arrested for distributing pornography. LOL

