Reverend Michael Bray is an American Lutheran minister who was convicted in 1985, along with two other defendants of two counts of conspiracy and one count of possessing unregistered explosive devices in relation to seven bombings of women's health clinics and three offices of women's health advocacy groups in Washington, D.C., Delaware, Maryland and Virginia. Bray and his wife, Jayne, are the named defendants in the Supreme Court decision Bray v. Alexandria, a ruling that determined pro-life demonstrators could not block entrances to abortion clinics in order to stop patients from entering to receive services.