May the government force someone to express a message to which they have strong moral objections? Most Americans would answer no, but that is exactly what Illinois officials have sought to do to pro-life doctors and pregnancy centers for over eight years—despite Alliance Defending Freedom having won a Supreme Court decision in 2018 that invalidated a similar law in California.
No one should be targeted by the government for peacefully living out their beliefs—least of all, those who offer free, lifesaving help to those in need.
What does Illinois SB 1564 do?
In 2016, the Illinois legislature passed SB 1564, an amendment to the Illinois Healthcare Right of Conscience Act. Passed under the guise of “protecting patients,” SB 1564 forces pro-life doctors and pregnancy centers to promote and refer for abortions, regardless of their moral objections.
While pro-life medical professionals know that abortion ends the life of an unborn child, SB 1564 forces them to lie and tell women there are so-called “benefits” to abortion and that abortion is a “treatment option” for pregnancy. The law also forces conscientious objectors to “refer,” “transfer,” or “provide written information” to a patient “about other health care providers who they reasonably believe may offer” abortion. These provisions go against the very mission of life-saving pregnancy centers.
The law was manufactured to target conscientious objectors like pro-life medical professionals and pregnancy centers, all because the government dislikes their views. And just a few years later, Illinois passed another law targeting pro-life pregnancy centers, regulating their speech when they advertise their services.
In 2015 and 2016, ADF sent letters to both state legislators and the governor warning them that SB 1564, if passed, would violate federal law. Unfortunately, in August 2016, the governor signed the amendment into law. ADF then filed federal and state lawsuits challenging SB 1564.
Thankfully, both state and federal courts agreed to put an injunction on the amendment, preventing it from going into effect. And after six years, pro-life pregnancy centers finally got their day in court in September 2023.
Who is opposing SB 1564?
ADF is representing the National Institute of Family and Life Advocates (NIFLA) and several pro-life pregnancy centers in a federal lawsuit challenging SB 1564. ADF is also representing the Pregnancy Care Center of Rockford and two other pregnancy centers in state court challenging the law.
One of these pregnancy centers, Mosaic Health, is led by Kathy Sparks Lesnoff. Kathy used to work at one of the largest abortion facilities in the Midwest. But after putting her faith in Jesus Christ and participating in an abortion for a woman who was 23 weeks pregnant, she knew that abortion was deliberately taking an unborn baby’s life, and she left the facility. But Kathy still felt called to help women who found themselves with an unplanned pregnancy.
So, in 1987, she founded Mosaic Health, a pro-life pregnancy center that provides help, services, and life-affirming choices to women facing unexpected pregnancies so they have the support they need throughout pregnancy and beyond. The center offers pregnancy testing, ultrasounds, counseling, car seats, diapers—the list goes on.
Since it was founded, Mosaic Health has helped over 19,000 women. Pro-life pregnancy centers like Mosaic serve people across the country. In 2022 alone, over 2,700 U.S. pregnancy centers served millions of women, men, and youth with services valued at over $358 million. Pregnancy centers are there to help when no one else is.
The government can’t force pro-life workers to promote abortion
In 2018, NIFLA, represented by ADF, won a landmark victory at the Supreme Court in NIFLA v. Becerra. In its ruling, the High Court confirmed that the First Amendment protects pro-life pregnancy centers from having to promote or refer for abortion.
In April 2025, a federal district court issued a ruling in NIFLA v. Treto that stopped short of blocking the referral requirement of SB 1564. But the court delivered an important free speech victory by permanently striking down the requirement that pro-life pregnancy centers speak about the so-called “benefits” of abortion.
No one should be forced to express a message that violates their convictions—not pro-life pregnancy centers or any other American.
National Institute of Family and Life Advocates v. Treto
- 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, 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.
