​​Happy Easter Monday! Welcome to the TMS Weekly Dispatch for April 21, 2025—with the latest news and updates from the front line, to keep you in-the-know on all things Thomas More Society. If you missed last week’s Dispatch, you may read it by clicking here.

Here’s a look back at the past week:

FEDERAL JUDGE ORDERS PAUSE TO ILLINOIS’ “ABORTION REFERRAL MANDATE” WHILE APPEAL MOVES FORWARD: Last week, TMS attorneys asked a federal judge to pause enforcement of Illinois’ “abortion referral mandate,” pending appeal—a request unopposed by Illinois’ attorney general. On Monday, April 21, U.S. District Court Judge Iain D. Johnston granted the request, issuing a court order putting the conscience-violating mandate on pause as the case continues in federal appeals court.

On April 4, Judge Johnston issued a split decision in Schroeder v. Treto, Jr. and NIFLA v. Treto, Jr., ruling that Illinois' statewide abortion referral mandate passed First Amendment scrutiny and can stay on the books—while striking down the state’s abortion promotion mandate, calling it unconstitutional compelled speech. Thomas More Society attorneys filed a notice of appeal in Schroeder v. Treto, Jr., in the first step of the continued legal battle against the Land of Lincoln’s abortion referral mandate. Illinois’ abortion referral mandate will now remain unenforceable for the duration of the appeals process.

ILLINOIS APPEALS FEDERAL COURT RULING STRIKING DOWN AS UNCONSTITUTIONAL STATE’S “ABORTION PROMOTION MANDATE”: In the other half of the case in Schroeder v. Treto, Jr., pertaining to the unconstitutional “abortion promotion mandate,” Illinois has filed a cross-appeal, challenging Judge Johnston’s April 4 ruling that struck down a portion of the Illinois law (SB 1564) that had required pro-life doctors and pregnancy centers speak about the so-called “benefits of abortion.”

That provision unconstitutionally compelled pro-life doctors to discuss the “benefits” of abortion, a requirement the federal district court found violated the First Amendment. Mario Treto, Jr., head of the state’s Department of Financial and Professional Regulation, filed a notice of cross-appeal on April 17, 2025, signaling the state’s intent to fight for reinstatement of this compelled speech mandate.

Earlier this month, Thomas More Society secured a partial victory in Schroeder v. Treto, a legal challenge to Illinois SB 1564, a state law which had amended the state's health care conscience protections and sought to force pro-life pregnancy centers and doctors to promote the so-called “benefits” of abortion and refer for abortions. The court protected pro-life individuals’ First Amendment right to not share abortion talking points when doing so would violate their sincerely held beliefs, but unfortunately also upheld the state’s abortion referral mandate, which Thomas More Society is appealing (see previous news item for further information).

‍TMS SCOTUS FRIEND-OF-THE-COURT BRIEF HIGHLIGHTS IMPORTANCE OF PARENTAL RIGHTS IN MAHMOUD V. TAYLOR: Earlier this year, TMS attorneys authored and filed a U.S. Supreme Court friend-of-the-court brief, on behalf of a coalition of interested parties, in support of parents' rights to safeguard their children from gender ideology in schools. The case, Mahmoud v. Taylor, will be argued before the U.S. Supreme Court on Tuesday, April 22. The case centers around a Maryland school board policy that eliminated the opt-out option for parents who opposed the addition of LGBTQ-themed books to their young children’s curriculum—blocking parents of Christian, Muslim, and Jewish faiths from exercising their ability to parent their children and be involved in their children's education in accordance with their religious beliefs.

The TMS brief argues that Mahmoud is a “pure opt-out case,” grounded in a longtime American tradition of respecting parental authority over that of the state regarding their children’s education. The brief also makes clear the distinction between opt-out requests and curricular disputes. Disagreement over curriculum minutiae might be complex and difficult to resolve, but the First Amendment-protected right of a parent to opt-out their child from a curriculum component owing to religious beliefs is a simple administrative matter that should be easily accommodated by schools.

According to the TMS brief:

‍The perceived specter hovering over the judiciary is that every time a parent is alarmed by a subject being taught in a state-funded school, the courts could be involving moral and metaphysical conundrums about which the method for resolution is not even apparent, much less clear. That feared nightmare—realistic or not—could not have come to reality in the case before this Court. That is because of the opt-out mechanism at play here, and its distinction from generalized curricular disputes.

WHO IS DENNIS CHRISTENSEN, ABORTIONIST AND DEFENDANT IN TMS LAWSUIT, RYLATT V. CHRISTENSEN?: Thomas More Society recently won a victory for Rockford, Illinois residents in a legal challenge against erroneous zoning approval for a “residential” abortion business owned by abortionist Dr. Dennis Christensen. Christensen’s business will undergo further investigation and must meet other permit specifications, or it will be shut down permanently.

But this isn’t the first time Thomas More Society has confronted this radical abortionist for flouting the law and endangering women. Who is Dr. Christensen and how does his abortion extremism extend far beyond thwarting Rockford’s zoning laws? Here are seven things to know about him:

1. Christensen’s previous Rockford-based abortion facility, Northern Illinois Women’s Health Center in Rockford, was closed in 2011 after a slew of health violations such as: failing to keep proper records, failure to monitor women properly after surgery, doctors lacking admitting privileges at local hospitals, and more. Thomas More Society represented Rockford citizens and a nurse who persuaded public health authorities to inspect the facility—which had not been inspected for 14 years.
2. Christensen is a resident of Wisconsin, not of Illinois, and therefore cannot apply for a residential business in the state.
3. He was featured in the 2006 documentary Lake of Fire, where he is shown examining the dismembered body parts of a 20-week-old child he aborted.
4. After Roe was overturned in 2022, Christensen came out of semi-retirement to circumvent Wisconsin abortion law and make his Rockford facility an abortion destination, with nearly half of patients come from out of state.
5. In 1999, he joined Planned Parenthood of Wisconsin in a lawsuit against a partial birth abortion ban in Wisconsin. He was 1 of only 2 abortionists in the state to conduct late-term abortions at the time.
6. In 2013, Christensen was involved in a battle over a Wisconsin law requiring abortionists to have admitting privileges at local hospitals. Christensen was denied privileges at three Milwaukee-area hospitals.
7. He has aborted over 100,000 preborn children during his career, gloating in a 2001 interview, “When I meet my maker, I think she’s [sic] going to say, ‘Way to go!’”

Thomas More Society will continue to hold abortionists like Christensen, as well as the entire abortion industry, accountable to the law.