Jane Doe No.1 v. Attorney General of the State of Indiana (2023)

FFRF joined a coalition of like-minded organizations in filing this amicus brief on behalf of the petitioners. This case centered around an Indiana law that required healthcare providers to bury or cremate fetal tissue remains from an abortion or miscarriage procedure regardless of the patients’ preference.

This brief took the position that Indiana’s law burdened patients’ religious beliefs and practices in violation of the Free Exercise Clause. It argued that there are a variety of religious beliefs regarding end-of-life rituals and that there isn’t one correct and dignified means of fetal tissue disposal.

Mia Guizzetti Hayes was the counsel of record on this case and filed it on behalf of FFRF and twenty-eight other organizations whose members were burdened by this law.


Freedom From Religion Foundation