Mary Doe ex rel. Satan?: Parody, Religious Liberty, & Reproductive Rights

47 Pages Posted: 31 May 2019 Last revised: 20 Jun 2021

Date Written: April 26, 2019


In 2015, a woman known as “Mary Doe” challenged a Missouri abortion restriction requiring her to wait seventy-two hours after receiving certain “informed consent” materials before she could obtain an abortion. Mary Doe challenged the restrictions in federal and state court on religious grounds as a member of the Satanic Temple. This paper examines the Satanic Temple’s litigation through the lens of parody — a literary technique that involves repeating another text’s form or content in order to critique it. Mary Doe’s litigation mirrored that of Burwell v. Hobby Lobby, in which a for-profit corporation claimed a religious accommodation from the ACA’s contraceptive mandate. The litigation forces two comparisons — between mainstream religious beliefs and other strongly held matters of conscience, and between abortion and other constitutional claims — and illuminates the “distortions” that often appear in reproductive rights litigation.

Keywords: abortion, reproductive rights, reproductive justice, First Amendment, RFRA, religious liberty, Hobby Lobby, Burwell v. Hobby Lobby, religious freedom, free exercise, Establishment Clause, Satanic Temple, parody, satire, irony, informed consent

Suggested Citation

Hammock Jones, Christen, Mary Doe ex rel. Satan?: Parody, Religious Liberty, & Reproductive Rights (April 26, 2019). 40 Columbia Journal of Gender and Law 46 (2020), Available at SSRN: or

Christen Hammock Jones (Contact Author)

Columbia University Law School ( email )

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