National Institute of Family and Life Advocates v. Treto

Illinois SB 1564 forces pregnancy care centers, medical facilities, and physicians who conscientiously object to involvement in abortions to adopt policies that provide women who ask for abortions with a list of providers “they reasonably believe may offer” them.

Case Timeline

• May 2015: ADF sent a letter to Illinois legislators on behalf of numerous pro-life physicians, pregnancy care centers, and pregnancy care center network organizations advising them that SB 1564 would violate federal law.
• May 2016: After the bill was passed, ADF sent a similar letter to Illinois Gov. Bruce Rauner.
• July 2016: Gov. Rauner signed SB 1564 into law, forcing medical facilities and physicians who conscientiously object to involvement in abortions to adopt policies that provide women who ask for abortions with a list of providers “they reasonably believe may offer” them.
• August 2016: ADF filed a lawsuit in state court against Illinois officials for forcing pro-life doctors and pregnancy care centers to promote abortion regardless of their ethical or moral views.
• September 2016: ADF filed a similar lawsuit in federal court.
• December 2016: An Illinois state court issued an injunction halting enforcement of SB 1564.
• July 2017: A federal district court issued an injunction halting enforcement of SB 1564.
• September 2023: After six years, a trial was held for the case in federal court.
• April 2025: The federal district court permanently blocked the portion of SB 1564 that required pro-life pregnancy centers to promote abortion. The court did not block the law’s referral requirement.
• May 2025: ADF attorneys filed their opening brief with the U.S. Court of Appeals for the 7th Circuit, appealing the part of the district court’s decision that upheld SB 1564’s referral requirement.
• January 2026: The U.S. Department of Health and Human Services sent a “notice of violation” to Illinois officials informing them that their state law violates the Weldon and Coats-Snowe Amendments.