The Devil Is in the Damages: Appeals Court Says Satanic Temple Lacks Standing in Indiana Case

Staff report

INDIANAPOLIS — January 6, 2026

A federal appeals court on Tuesday upheld the dismissal of a lawsuit by The Satanic Temple seeking to block enforcement of parts of Indiana’s 2022 abortion law that restrict the use of telehealth for medication abortions, ruling the group lacked legal standing to sue.

In a unanimous decision issued Jan. 6, the U.S. Court of Appeals for the Seventh Circuit affirmed a lower-court ruling that The Satanic Temple, a Massachusetts-based nonprofit religious organization, did not show a sufficiently concrete injury to itself or identify a specific member harmed by the challenged provisions.

The case centered on changes Indiana enacted through Senate Bill 1, which took effect Sept. 15, 2022. Among other requirements, Indiana law mandates that abortion-inducing drugs be provided through an in-person process involving an Indiana-licensed physician and generally bars the use of telehealth or telemedicine for abortions.

The Satanic Temple sued Indiana Attorney General Todd Rokita and Marion County Prosecutor Ryan Mears in their official capacities, seeking an injunction against enforcement of a felony penalty statute tied to violations of the abortion law, as well as declaratory relief under Indiana’s Religious Freedom Restoration Act.

In its opinion, the appeals court said the organization failed to establish “associational standing” because it did not identify an individual member who was injured or faced an imminent injury, and instead relied on probabilistic claims. The court cited U.S. Supreme Court precedent requiring organizations to identify affected members in most circumstances, rather than relying on statistical assumptions.

The panel also found the organization lacked standing in its own right because the relief it requested would not redress the broader legal barriers to the conduct it described. The court noted that, beyond the specific criminal enforcement provision The Satanic Temple sought to enjoin, other Indiana statutes separately prohibit telehealth abortions, including a provision stating that telehealth “may not be used to provide any abortion,” including writing or filling a prescription intended to result in an abortion.

“Even if” the felony penalty statute at issue were blocked, the court said, other unchallenged provisions would remain in place, undermining causation and redressability — two core requirements for standing in federal court.

The case was argued Oct. 24, 2024, and decided by a panel including Judges Frank Easterbrook, Michael Kirsch and Sarah E. Pryor, with Pryor authoring the opinion.

Rokita’s office celebrated the decision in a press release that used unusually combative language, describing the lawsuit as “ridiculous from the start” and labeling the ruling a major victory for the state’s abortion restrictions.

Because the appeals court dismissed the case on jurisdictional grounds, it did not rule on the underlying merits of The Satanic Temple’s constitutional and statutory arguments.

The lawsuit grew out of The Satanic Temple’s claims that its members’ beliefs support what it calls a “Satanic Abortion Ritual,” and that Indiana law unlawfully blocks telehealth access to medication abortion. The Seventh Circuit opinion described the organization’s current telehealth clinic operations as limited to patients physically located in New Mexico, and said the group does not operate — and does not intend to start — an in-person abortion clinic in Indiana.

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