A federal appeals court has directed a lower court to reexamine whether The Satanic Temple (TST) has legal standing to challenge Idaho’s strict abortion ban. This development could allow the group another chance to press its provocative constitutional claims.
The case, The Satanic Temple v. Labrador, asserts that Idaho’s law violates several constitutional protections—claiming the abortion ban constitutes a taking of the “economic value of a woman’s uterus” under the Fifth Amendment, amounts to a form of slavery under the Thirteenth Amendment, and discriminates under the Fourteenth Amendment by exempting survivors of rape and incest. TST positions abortion as a religious practice central to its doctrine of bodily autonomy.
A panel of the Ninth Circuit found that TST lacks both associational and organizational standing. The group has no clinic, staff, or patients in Idaho and failed to identify any specific Idaho member harmed by the law. Its statistical projections—estimating that 27 members in Idaho might become “involuntarily pregnant” annually—were deemed too speculative to meet Article III requirements.
Despite affirming the dismissal, the court sent the case back to the district court to decide whether the dismissal should be without prejudice, allowing TST to refine its claims and potentially refile.
Attorney General Raúl Labrador hailed the ruling as a defense of Idaho’s pro-life values, stating: “The Ninth Circuit Court of Appeals correctly found that the plaintiff lacked standing to challenge Idaho’s laws protecting mothers and preserve the sanctity of life.”
