I am sure this has been discussed here before.
but:
The short answer to the question is no. a jewish cemetery could not have a hard and fast rule like that.
The longer answer.
A non practicing Jew may not buried next to one who was observant of the torah and its laws. The torah forbids Jews from tattooing.
but
The mere presence of a tattoo does not prove that the deceased was a non-practicing Jew at the time of his death
and even a non-practicing jew may and should be buried in a jewish cemetery, though he would not be given an adjoining plot to one who was observant.
for a still longer answer stay tuned, others will post.
and now it is time for me to go back on the wagon.