The court ruled the group cannot sue because it failed to name a single pregnant member affected by the law.
The United States Court of Appeals for the Seventh Circuit affirmed the dismissal of a lawsuit filed by The Satanic Temple (TST) against Indiana officials. TST argued that Indiana’s ban on telehealth abortions violated its religious rights. The court ruled that TST lacked standing because it relied on statistical probability rather than identifying specific injured members. The judges also found that TST had no concrete plans to violate the law. This meant the threat of prosecution was speculative rather than imminent. The decision confirms that organizations must identify actual victims or demonstrate specific intent to break the law to challenge state statutes in federal court.
Case Information:
• Case Caption: Satanic Temple, Inc. v. Rokita
• Case Number: No. 23-3247
• Court: United States Court of Appeals for the Seventh Circuit
• Date Decided: January 6, 2026
Yes, the Seventh Circuit Court of Appeals ruled that The Satanic Temple lacks the legal standing to challenge Indiana’s abortion laws. The court determined that the organization failed to identify any specific member who was actually injured by the statutes and could not prove it faced a credible threat of prosecution.
This ruling clarifies the strict requirements for “associational standing” in federal courts. It prevents organizations from suing based on the statistical likelihood that a member might be harmed. The decision requires plaintiffs to identify real individuals with actual injuries before a court will hear the merits of a constitutional challenge.
What are the facts of the case?
The Satanic Temple is a non-profit religious corporation that advocates for bodily autonomy. It sought to provide telehealth medical services to its members in Indiana to facilitate a “Satanic Abortion Ritual”. This ritual involves the use of abortion-inducing drugs.
Indiana Senate Bill 1 amended state law to prohibit the use of telehealth for abortions. The law requires that physicians examine patients in person and that patients consume the medication in the physician’s presence. Violating these rules is a felony. TST sued Indiana Attorney General Todd Rokita and Marion County Prosecutor Ryan Mears to stop enforcement of these criminal penalties.
Why did the court reject the statistical argument?
TST argued it had standing to sue on behalf of its members. The organization relied on a declaration from a doctor who estimated that approximately 94 of TST’s 11,300 Indiana members were likely to become involuntarily pregnant in a given year. TST called this “probabilistic standing”.
The court rejected this approach. The judges noted that TST failed to identify a single specific member who was actually pregnant and seeking an abortion. The opinion stated that “speculation through statistics” does not satisfy the constitutional requirement to show an actual injury. Without identifying an affected member, the court cannot exercise jurisdiction.
Did the group face a threat of prosecution?
TST also claimed it had standing to sue on its own behalf because it feared prosecution for providing telehealth abortions. A plaintiff can sometimes sue before a law is enforced if they face a “credible threat” of criminal sanctions.
The court found this fear was not grounded in reality because TST lacked “concrete plans” to violate the law. TST admitted it does not operate a licensed abortion clinic in Indiana and has no ties to hospitals in the state. Since the organization lacked the necessary infrastructure to perform abortions even without the telehealth ban, the court concluded it was not “certainly impending” that they would violate the law and be prosecuted.
How do other laws affect the outcome?
The court noted that even if it struck down the specific criminal statute TST challenged, other Indiana laws would still prevent the organization from operating. For example, Indiana law requires physicians performing abortions to have hospital admission privileges. Another statute explicitly bars telehealth for abortion purposes.
TST did not challenge these other statutes. The court reasoned that a victory in this lawsuit would not actually solve TST’s problem because these other laws would still prohibit their proposed conduct. This lack of “redressability” was another reason the court dismissed the case.
What happens next?
The Seventh Circuit affirmed the district court’s dismissal of the lawsuit. This ends the case in the appellate court. TST cannot proceed with its claims in Indiana federal court unless the Supreme Court of the United States agrees to review the decision. The ruling leaves the Indiana laws prohibiting telehealth abortions in full effect.
Commentary
This case highlights the procedural gatekeeping function of the federal judiciary. Courts require an actual “case or controversy” to act. They do not issue advisory opinions on laws simply because an organization disagrees with them. The plaintiff must show that a specific person is actually being harmed. TST’s reliance on statistical probability was a fatal error. Courts deal in facts and individuals. They rarely accept aggregate data as a substitute for a named plaintiff.
The failure to establish “redressability” is equally damaging to the plaintiff’s cause. A lawsuit must be able to fix the injury it complains of. TST attacked one specific criminal provision but ignored the web of regulatory statutes that also blocked their operations. It is futile for a court to strike down one barrier if three others remain standing. Strategic litigation requires targeting the entire regulatory scheme.
The court’s dismissal of the pre-enforcement challenge also serves as a warning to future litigants. You cannot claim you are afraid of being arrested for a crime you are incapable of committing. TST admitted it had no doctors or clinics in Indiana. Therefore, the state had no reason to prosecute them. A “credible threat” of prosecution requires the means and intent to break the law. TST showed neither.
Finally, this ruling avoids the substantive religious freedom questions entirely. By disposing of the case on standing grounds, the court did not need to decide if the “Satanic Abortion Ritual” is protected by the First Amendment. This is a common judicial tool. Courts prefer to resolve cases on procedural grounds when possible. It leaves the core constitutional questions for a future case with a proper plaintiff.
Citations
• [1] Satanic Temple, Inc. v. Rokita, No. 23-3247 (7th Cir. Jan. 6, 2026).
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Disclaimers:
• This article was assisted by AI.
• This does not constitute legal advice. Readers are encouraged to talk to licensed attorneys about their particular situations.
Tags: Satanic Temple, Indiana abortion law, Seventh Circuit, standing doctrine, telehealth abortion