In
Doe v. Parson, (8th Cir., June 9, 2020), the U.S. 8th Circuit Court of Appeals rejected claims by a member of the Satanic Temple that Missouri's abortion informed consent law violates her 1st Amendment rights. Plaintiff argues that the state's informed consent booklet violates the Establishment Clause by promoting "Catholic dogma" about when life begins. The court rejected that argument, saying in part:
Some religions, including Catholicism, embrace the view that life begins at conception. Others, like Doe’s Satanism, do not. Any theory of when life begins necessarily aligns with some religious beliefs and not others. So under Doe’s theory, Missouri’s only option would be to avoid legislating in this area altogether.
The court also rejected plaintiff's argument that the requirement that she certify that she has had an opportunity to view and ultrasound and the informed consent booklet violates her free exercise rights. The court said in part:
Doe makes no argument ... that the informed-consent law is anything other than “neutral” and “generally applicable.”
