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The complaint asks the court to immediately block the provisions of Texas House Bill 2 with the most immediate and far-reaching impact on women's health before they take effect October 29, 2013, including:

• Medically unnecessary restrictions on the use of medication abortion, which is a safe and effective method to end an early pregnancy. These restrictions would threaten women's health, and are contrary to good medical practice.
• A requirement that only physicians who provide abortions – but not any other medical providers, - obtain admitting privileges at a local hospital. This requirement would not make abortion care any safer. Abortion is already an incredibly safe procedure with less than half of one percent of patients seeking care at a hospital following the procedure. Instead, this requirement is designed to force many safe and experienced providers out of practice.

The challenged provisions are part of a package of legislation signed by Governor Rick Perry on July 18, 2013, following a special legislative session. The law was opposed by 80 percent of Texas, and medical experts in Texas and across the country, including the American Congress of Obstetricians and Gynecologists, Texas Medical Association, and Texas Hospital Association, also publicly opposed the law because it provides no medical benefit to women and will actually jeopardize women's health and safety.