In 2015, Tennessee passed a law requiring a woman seeking an abortion to have mandatory counseling and a 48 hour waiting period before the abortion. In October, 2020, a US District Court struck down the law, saying that it imposed an undue burden for women seeking an abortion, that logistical and scheduling problems could cause delays of weeks which could push a woman beyond the time frame for an abortion by pills and force her to have a surgical abortion, which is more complicated and places her at greater risks to have complications.

This decision was appealed and reversed and the law placed back into effect while the state took its case to the Appeals Court. On June 2, Tennessee began arguments before the court, seeking to have the law permanently restored.