The Seventh Circuit Court of Appeals affirmed a district court's dismissal of a religious freedom challenge to Indiana's telehealth abortion restrictions, ruling that the Satanic Temple, Inc. lacked standing to bring the lawsuit on behalf of its members.
In a decision issued Jan. 6, 2026, the three-judge panel upheld the U.S. District Court for the Southern District of Indiana's ruling in favor of Indiana Attorney General Todd Rokita and Marion County Prosecutor Ryan Mears. The case centered on Indiana Senate Bill 1, which took effect Sept. 15, 2022, and significantly restricted how abortion medication can be administered in the state.
The Satanic Temple, a Massachusetts nonprofit corporation organized as a religious institution, sought to ensure its Indiana members could access telehealth medical services to receive medication that induces abortion. The organization argued that Indiana's criminal penalties for such services violated the religious freedom rights of its members.
Under Indiana Code Section 16-34-2-1, abortions in Indiana must be performed by an Indiana-licensed physician in a hospital or an outpatient surgical center owned by a hospital. For abortion-inducing drugs specifically, the law requires a physician to first examine a woman in person, dispense the drug to the woman in person, and have the woman consume the medication under direct physician supervision.
The Satanic Temple filed suit in federal court challenging Indiana Code Section 16-34-2-7(a), which criminalizes violations of these requirements. The organization sought an injunction against enforcement of the criminal penalties, arguing on behalf of both itself and its members that the restrictions violated their constitutional rights to religious practice.
Defendants moved to dismiss the complaint, asserting that the Satanic Temple lacked standing to sue both on behalf of its members and in its own capacity. The district court agreed with this argument and granted the motion to dismiss.
On appeal to the Seventh Circuit, the panel of Circuit Judges Easterbrook, Kirsch, and Pryor reviewed the standing determination. In the opinion authored by Circuit Judge Pryor, the court analyzed whether the Satanic Temple met the constitutional requirements for standing under Article III of the U.S. Constitution.
Standing doctrine requires plaintiffs to demonstrate they have suffered an injury in fact that is concrete and particularized, that the injury is traceable to the defendant's conduct, and that the injury is likely to be redressed by a favorable judicial decision. When an organization seeks to sue on behalf of its members, it must meet additional requirements for associational standing.
The case represents the latest intersection of religious freedom claims and state abortion regulations since the Supreme Court's decision in Dobbs v. Jackson Women's Health Organization overturned Roe v. Wade in 2022. Various religious organizations across the political spectrum have challenged state abortion laws on First Amendment grounds, with mixed results in federal courts.
The Satanic Temple has pursued similar litigation strategies in other states, arguing that abortion restrictions interfere with their religious beliefs and practices. The organization maintains that access to abortion care is part of their religious doctrine, making state restrictions a violation of the Free Exercise Clause of the First Amendment.
Indiana's telehealth restrictions were part of a broader package of abortion regulations enacted following the Dobbs decision. The law eliminates the possibility of receiving abortion medication through telemedicine consultations, requiring in-person physician visits and supervision throughout the process.
The ruling affirming dismissal means the Satanic Temple's challenge to Indiana's criminal penalties will not proceed to trial on the merits. The organization could potentially appeal the decision to the Supreme Court, though the high court is not required to hear the case.
For Indiana officials, the decision represents a victory in defending the state's abortion regulations against constitutional challenges. Attorney General Rokita has been a vocal defender of the state's restrictions and has indicated his office will continue to enforce the criminal penalties.
The case also highlights the complex legal landscape surrounding abortion access in post-Dobbs America. As states implement varying levels of restrictions, federal courts continue to grapple with constitutional challenges based on different legal theories, including religious freedom, due process, and equal protection claims.
The Seventh Circuit's decision adds to a growing body of case law examining how courts will evaluate standing requirements in abortion-related litigation. The ruling suggests federal courts may scrutinize more carefully whether organizations have sufficient connection to alleged harms to bring constitutional challenges.
The decision represents a procedural victory for Indiana rather than a ruling on the substantive constitutional questions raised by the Satanic Temple. The court's finding of lack of standing means the religious freedom arguments were never reached or decided on their merits.