[nwrep]

Please read the case. Public safety is exactly the issue here, same as your example...

[Alberta's Child]

In the case of a fire code, the state has a compelling interest in protecting neighboring properties and firefighters responding to the scene of a fire even if the facility is used entirely by a private religious organization and excludes people from other denominations as a matter of course.

I don't see how a private playground can have a similar "public safety" angle to it.

Perhaps I'm overlooking something here. Does this case involve a church that built and maintained a playground that is open to the public?