A Colorado court, in Bella Health and Wellness et al. v. Weiser et al., has held that a state statute banning "abortion reversal" practices violates the plaintiff's religious exercise rights. The court applied strict scrutiny and held (all internal citations removed):
Defendants have not carried their burden to show that its stated interests can survive this exacting inspection. To begin, Defendants’ asserted interests remain overly broad. Though it may be true that States “have a compelling interest in the practice of professions within their boundaries,” and in protecting “the people of this state from unauthorized, unqualified, and improper application of services,” those broadly formulated interests do not suffice where, as here, religious practice has been singled out for differential treatment. And while I would generally have no trouble giving the state “wide discretion to pass legislation in areas where there is medical and scientific uncertainty,” the fact that Plaintiffs’ religiously compelled practice has been targeted in this case demands a more searching scrutiny. Section Three is also “not drawn in narrow terms to accomplish” the interests proffered by Defendants. Most obviously, even accepting Defendants’ rationale that it is necessary to prohibit medical practices that potentially pose safety and efficacy risks, Section Three is vastly underinclusive. * * *
Nor can the Defendants show that the purported goals of Section Three could not be accomplished through less restrictive means. To the extent Section Three was intended to prevent patients from undergoing treatments without full knowledge of safety or efficacy concerns, why would that interest not be equally served by an “informed consent law to ensure that women seeking APR are adequately informed of its risks and benefits”? For all of these reasons, Defendants have not carried their burden to show that Section Three is narrowly tailored to serve a compelling government interest. Section Three therefore fails strict scrutiny and the Plaintiffs named in this case are entitled to a narrow injunction enjoining its enforcement against them.