Doe performed TST's abortion ritual, a ceremonial affirmation of self-worth and bodily autonomy that integrates the abortive process. Prior to filing the lawsuit, TST's attorney sent a letter to the Texas Health and Human Services Commission, which demanded an exemption from the abortion restrictions on behalf of Ann Doe. TST's attorney explained:

"The abortion ritual (1) requires an abortion; and (2) affirms her religious subscription to TST's Third and Fifth Tenets. But before Ms. Doe can get her abortion–and therefore participate in the abortion ritual–the government has required that she get a sonogram… [ These ] requirements substantially interfere with Ms. Doe's religious beliefs and practices for two reasons. First, the requirements are a precondition to Ms. Doe's ability to participate in a religious ceremony. It is a substantial interference per se for the state to place a regulatory hurdle–one that costs money–in front of a religious exercise. The state might as well tax and regulate Mass."

TST spokesperson Lucien Greaves says, "I am sure Texas Attorney General Ken Paxton, who famously spends a good deal of his time composing press releases about Religious Liberty issues in other states, will be proud to see that Texas's robust Religious Liberty laws, which he so vociferously champions, will prevent future Abortion Rituals from being interrupted by superfluous government restrictions meant only to shame and harass those seeking an abortion."