This article originally appeared in the Thomas More Society 2025 Impact Report. To explore the full Impact Report, click here.

Oksana Hulinsky used to spend her mornings on the sidewalk outside a Westchester County, New York abortion facility, offering pamphlets, conversation, and hope to women walking in. Motivated by her faith, she has been doing this gentle and peaceful work for years.

She never blocked or threatened anyone.

But now, Oksana sits in her car and does the last thing she’s allowed to do. She prays.

In 2022, Westchester County passed a law to silence ministries like hers—not by banning sidewalk counseling outright, but by demanding something no human being can do: read minds. Under the law, it is a crime to continue speaking to someone outside an abortion facility after they make an “implied request to cease.” Not a verbal request or a hand raised in objection. An implied one—an unspoken, internal thought that sidewalk counselors are somehow expected to detect, or face criminal prosecution and up to a year in jail.

What does an “implied request to cease” actually look like? When pressed in court, even the county’s own attorneys couldn’t define the standard they were asking a judge to enforce. County counsel conceded during proceedings that someone merely walking around a sidewalk counselor could constitute an implied request to stop speaking. Asked whether a blank stare would trigger the law, the county’s lawyer admitted it was a “close question.” Taking just a few steps alongside another person, they acknowledged, could qualify as criminal “following.” The law also criminalizes speech that “alarms or seriously annoys” another person—without defining what those words mean.

Westchester County has been unable to identify a single instance—before or after the law’s passage—of unlawful harassment by pro-life advocates on public sidewalks in the county. The county manufactured a problem that didn’t exist, then crafted a law so vague that it silenced the very people it targeted. It worked. Threatened with criminal charges, Oksana and fellow counselor Regina Molinelli stopped sidewalk counseling entirely. The women who might have heard their message now walk into the facility without ever knowing someone was there who cared.

In March 2025, Thomas More Society attorneys won a federal court ruling that one portion of the law “criminalized large swaths of protected speech” in violation of the First Amendment—and in August, the county was found liable for violating First Amendment rights. But the court declined to strike down the “implied request to cease” provision. TMS has now appealed to the Second Circuit.

“This law turns ordinary conversation into a guessing game with jail time, financial ruin, and the potential loss of preborn life as the penalty,” said Christopher Ferrara, TMS Senior Counsel. “Pro-life sidewalk advocates are peaceful, compassionate, and perhaps persistent—but they are not the mind readers Westchester County demands they be.”

Dismantling No-Speech Zones

The Westchester case is part of Thomas More Society’s broader campaign against the “bubble zones” and no-speech zones that municipalities across the country have enacted to silence sidewalk counselors—in the very places where the First Amendment’s protections should be at their strongest.

In December 2025, TMS secured a landmark victory when the U.S. Court of Appeals for the Eleventh Circuit struck down the City of Clearwater, Florida’s “vehicular safety zone” ordinance as a violation of the First Amendment. The city had banned pedestrians from a stretch of public sidewalk outside an abortion facility during business hours, preventing Florida Preborn Rescue’s sidewalk counselors from distributing literature or speaking with women arriving by car.

Applying the U.S. Supreme Court’s precedent in McCullen v. Coakley, the Eleventh Circuit ruled that the ordinance burdened far more speech than necessary and ignored less restrictive alternatives that could address safety concerns without silencing peaceful advocacy. The court ordered entry of a permanent injunction protecting the Florida Preborn Rescue sidewalk counselors represented by TMS.

In California, Thomas More Society is pressing the fight in the Ninth Circuit on behalf of Roger Lopez, a San Diego sidewalk counselor whose fifteen-year ministry has been decimated by the city’s 100-foot no-speech zone—a law that exempts abortion facility employees from all restrictions while threatening pro-life counselors with jail for offering a leaflet.

For Oksana, Regina, Roger, and for the women who never get to hear that someone on the sidewalk cares, the no-speech zones are coming down—one city at a time, until the Supreme Court finally revisits Hill v. Colorado.