An Arizona child abuser reportedly confessed to clergy religious leaders that he had sexually abused his own daughter.
The leaders did not report him.
The abuse remained hidden until federal investigators discovered a video online years later.
On July 30, 2026, the Arizona Supreme Court ruled that the religious leaders did not have a legal duty to report the confessed abuse under Arizona’s clergy-reporting exemption. The court also affirmed summary judgment in favor of The Church of Jesus Christ of Latter-day Saints and the bishops who received the disclosures.
That may be the legal result under Arizona’s current statute and the court’s interpretation of the First Amendment. It should never be confused with a child-protection victory.
It is not.
This ruling exposes a dangerous gap between what the law may permit and what protecting a child demands. It also demonstrates how clergy-reporting exemptions can block civil accountability when an institution allegedly knows that a child faces sexual abuse but places confidentiality ahead of intervention.
At Andreozzi + Foote, we believe religious liberty and child protection should not be treated as opposing values. Faith institutions can preserve the spiritual purpose of confession while still maintaining one nonnegotiable rule:
When a child is being sexually abused, protecting that child must come first.
Key Takeaways From the Arizona Clergy Reporting Ruling
- The Arizona Supreme Court ruled that the bishops could withhold reporting of abuse disclosed through a confession or confidential religious communication.
- The court held that judges and juries generally cannot second-guess a clergy member’s interpretation of religious doctrine.
- The decision affirmed summary judgment against the survivors on claims that included negligence, breach of fiduciary duty, and civil conspiracy.
- The ruling does not grant religious institutions complete immunity from civil lawsuits.
- The exemption does not necessarily protect information obtained through personal observations, secular communications, or sources outside a protected confession.
- Civil claims may still exist when an institution negligently supervises an offender, provides access to children, conceals nonprivileged information, retaliates, commits fraud, or violates other duties imposed by state law.
- The ruling applies directly to Arizona law. Other states have different mandatory-reporting statutes and clergy-confidentiality rules.
The decision should prompt lawmakers to remove or sharply narrow clergy exemptions when a child faces current or future danger
What Happened in the Arizona LDS Church Abuse Case?
The case is Jane Doe I, Jane Doe II, and John Doe v. The Corporation of the President of The Church of Jesus Christ of Latter-day Saints, Arizona Supreme Court No. CV-25-0213-PR.
According to the Arizona Supreme Court’s opinion, Paul and Leizza Adams had six children. Three of their children later became plaintiffs in the civil action.
Around 2011, Paul Adams met privately with Bishop John Herrod and disclosed that he had sexually abused one of his children. Bishop Herrod then scheduled another meeting with Adams and his wife. Adams reportedly disclosed the abuse again during that meeting.
When Bishop Robert “Kim” Mauzy later assumed leadership of the congregation, Herrod informed him about Adams’ disclosures. Mauzy convened a church disciplinary council. Adams again acknowledged his abuse before several council members, and the church excommunicated him.
Excommunication removed Adams from the church. It did not summon law enforcement, initiate a child-protection investigation, or immediately remove the children from danger.
According to the court, the bishops maintained that they learned about the abuse only through communications they considered confidential under church doctrine.
In 2017, the Department of Homeland Security discovered a video of the abuse online. Authorities then charged Paul and Leizza Adams with crimes connected to the abuse. Leizza Adams pleaded guilty and received a prison sentence. Paul Adams admitted the abuse to law enforcement but died by suicide in jail before trial.
The children subsequently brought civil claims against the church, the bishops, and other parties. Their claims against the church defendants included negligence, breach of fiduciary duty, and civil conspiracy. At least part of their case rested on the defendants’ alleged failure to comply with Arizona’s child-abuse reporting law.
The trial court entered summary judgment for the church defendants. An intermediate appellate court reversed that decision in 2025, finding factual questions that a jury should consider.
The Arizona Supreme Court has now vacated the appellate decision and reinstated summary judgment for the church defendants.
That means the survivors did not receive a trial against those defendants on these claims. A jury will not hear the evidence and determine whether the church defendants should bear civil responsibility under the theories resolved by the ruling.
What Does Arizona’s Mandatory-Reporting Law Say?
Arizona law generally requires any person who reasonably believes that a child is or has been abused to make an immediate report to law enforcement or the Arizona Department of Child Safety.
However, the statute contains a clergy exemption.
Under Arizona Revised Statutes § 13-3620, a clergy member who receives a confession or confidential communication in a religious capacity may withhold reporting when the clergy member determines that confidentiality is “reasonable and necessary” within the concepts of the religion.
The statute also states that this exemption applies to the confession or confidential communication—not to a clergy member’s independent observations of a child.
This distinction matters.
A clergy member who personally observes injuries, threatening behavior, grooming, a child’s deteriorating condition, or other evidence may possess information outside the protected communication. Likewise, information received through administrative, supervisory, personnel, or other secular channels may require a separate legal analysis.
The danger arises when institutions attempt to label an expanding circle of knowledge as religiously confidential.
What Did the Arizona Supreme Court Decide?
The court addressed three central questions.
First, it held that the First Amendment generally prevents courts and juries from examining whether a clergy member correctly applied religious doctrine when deciding that withholding a report was “reasonable and necessary.”
Second, the court defined a confession as a confidential acknowledgment of a crime, sin, or fault made to clergy for absolution. It defined a confidential communication as private speech or correspondence made under circumstances indicating that it was intended only for the people addressed.
However, the court also required substantial deference to a religious institution’s own doctrinal understanding of those terms.
Third, the court held that religious institutions generally have the right to determine who qualifies as clergy. Courts ordinarily cannot second-guess that designation unless evidence shows fraud or collusion for a secular purpose.
The bishops stated that church doctrine required them to keep Adams’ disclosures confidential. The court concluded that it was constrained to accept that determination on the record before it.
The court emphasized that the case concerned its interpretation of Arizona law and federal constitutional principles—not the wisdom of Arizona’s public policy or the underlying merits of the children’s experiences.
That distinction may be doctrinally important to a court.
It offers little comfort to a child who remained in danger.
A Legal Right to Remain Silent Is Not a Moral Duty to Do So
The court ruled that the bishops were legally permitted to withhold the report. The court did not rule that reporting the abuse would have violated Arizona law.
Those are not the same thing.
The statute says qualifying clergy may withhold a confidential communication when they determine that doing so is reasonable and necessary within the religion. It does not appear to command silence in every case.
This case therefore raises a question that reaches far beyond technical statutory interpretation:
When an adult admits that a child is being sexually abused, why would any child-serving institution choose a policy of silence?
Religious freedom protects belief, worship, doctrine, and internal religious governance. It should not become a shield that leaves children trapped with an admitted abuser.
A confession may serve a spiritual purpose. However, repentance without child protection is not accountability. Counseling an offender does not replace a trained child-abuse investigation. Excommunication does not remove a perpetrator from a home. Internal discipline does not protect children who remain under an offender’s control.
Child sexual abuse is not merely a private sin.
It is a crime against a child. A profound violation of bodily autonomy and trust. It can cause lifelong psychological, physical, relational, educational, and financial harm.
When institutions reduce abuse to an internal spiritual matter, they center the offender’s relationship with the institution. They do not center the child’s safety.
Why the Arizona Ruling Creates a Dangerous Confessional Loophole
The Arizona clergy reporting ruling creates several serious child-protection concerns.
Abusers May Learn That Confession Can Provide Cover
Confession should create a pathway toward accountability. A broad clergy exemption can produce the opposite result.
An offender may disclose abuse in a religious setting, appear remorseful, participate in counseling, or accept internal discipline while continuing to have access to the victim. If the disclosure remains sealed and no trained investigator evaluates the danger, the offender may retain control over the child and the evidence.
The system may then mistake acknowledgment for safety.
It is not safety.
Religious Institutions May Become the Final Judges of Their Own Reporting Duties
The court held that judges and juries generally cannot decide whether clergy correctly applied religious doctrine when invoking Arizona’s exemption.
That creates a troubling accountability problem. If the institution defines the communication, identifies the clergy, interprets the doctrine, and decides whether silence was religiously necessary, an injured child may have little meaningful opportunity to challenge that decision.
Civil discovery may also become more difficult. Institutions may resist producing internal records, disciplinary documents, communications with legal advisers, or evidence about how leaders interpreted their own policies.
The institution could effectively control both the information and the legal characterization of that information.
No organization should be permitted to transform internal secrecy into external immunity.
Internal Discipline Can Be Mistaken for Child Protection
Removing an offender from membership or leadership may be appropriate. It is not a substitute for contacting authorities.
Law enforcement and child-protection agencies can:
- Interview victims using trained professionals;
- Assess the safety of other children;
- Preserve digital and physical evidence;
- Identify additional victims;
- Obtain search warrants;
- Restrict an offender’s access to children;
- Coordinate medical and mental health services; and
- Pursue criminal accountability when the evidence supports it.
A religious disciplinary body cannot replace those functions.
A church may decide who remains a member. It should not decide, by itself, whether an admitted child abuser remains free from investigation.
The Civil-Law Consequences for Survivors
The Arizona Supreme Court’s decision has implications far beyond mandatory reporting.
Civil lawsuits often provide the only forum where survivors can obtain records, question institutional decision-makers, expose systemic failures, and pursue compensation for the harm caused by abuse.
That matters especially when:
- The perpetrator dies before trial;
- Criminal charges are never filed;
- Prosecutors cannot prove a case beyond a reasonable doubt;
- The institution controlled critical evidence;
- The abuse happened many years earlier;
- The perpetrator has few assets; or
- Internal practices allowed the abuse to continue.
In this case, the civil plaintiffs asserted negligence, breach of fiduciary duty, and civil conspiracy claims. The court affirmed summary judgment for the church defendants where those claims relied on the alleged failure to report the confidential disclosures.
The decision may make similar Arizona cases harder to pursue when the institution can characterize its knowledge as a protected religious communication.
It may also affect a survivor’s ability to establish:
- When the institution first learned about the abuse;
- Which leaders received the information;
- Whether information moved through institutional channels;
- Why leaders chose not to report;
- If the offender presented an ongoing risk;
- Or the institution placed its reputation or liability concerns ahead of safety; and
- If earlier intervention could have prevented additional abuse.
Civil justice depends on evidence. An expansive confidentiality shield can deprive survivors of both the evidence and the opportunity to present it to a jury.
What the Arizona Ruling Does Not Do
The ruling is serious, but survivors and advocates should not interpret it more broadly than the court wrote it.
It Does Not Create Nationwide Immunity
The Arizona Supreme Court interpreted Arizona law. Courts in other states do not have to apply Arizona’s clergy exemption.
Mandatory-reporting laws vary significantly across the country. Some states treat clergy as mandated reporters. Some recognize a narrow privilege. Others preserve broader clergy exceptions.
A survivor’s civil options therefore depend heavily on where the abuse occurred, where the institution operated, what information it possessed, and how that state defines institutional duties.
It Does Not Give Religious Institutions Complete Immunity
The court expressly stated that religious institutions do not enjoy general immunity from secular laws.
Courts may still resolve disputes involving religious organizations through neutral legal principles that do not require a judge or jury to interpret religious doctrine.
Depending on the facts and governing state law, potential claims may involve:
- Negligent hiring, retention, or supervision;
- Negligent placement of an offender in ministry;
- Failure to enforce child-safety policies;
- Misrepresentation or fraudulent concealment;
- Breach of a voluntarily assumed duty;
- Failure to warn about a known danger;
- Premises liability;
- Agency or vicarious liability;
- Civil conspiracy;
- Intentional infliction of emotional distress; or
- Violations of state-specific child-protection statutes.
The viability of any claim depends on the jurisdiction and the evidence.
It Does Not Protect Independent Observations
Arizona’s statute limits the exemption to the confession or confidential communication. It does not extend the exemption to a clergy member’s personal observations of the child.
Signs of injury, direct disclosures from a child, digital evidence, witness reports, prior complaints, personnel records, or information learned outside a religious confession may fall outside the exemption.
Institutions cannot automatically place every fact concerning an offender under a single umbrella of spiritual confidentiality.
It Preserves a Narrow Fraud-or-Collusion Exception
The Arizona Supreme Court recognized that religious-autonomy protection may not apply when evidence results from fraud or collusion undertaken for a secular purpose, such as avoiding legal responsibility.
The court found no such evidence in the record before it.
Future cases may present different evidence.
For example, a court may need to distinguish a good-faith doctrinal determination from an institution that retroactively characterizes communications as religious, manipulates records, coordinates misleading testimony, or invokes doctrine primarily to evade secular duties.
The court described this avenue as narrow. Survivors’ attorneys should nevertheless investigate it carefully when the evidence supports doing so.
Religious Freedom Must Not Mean Freedom From Child-Safety Standards
No one should force a faith community to abandon its theology.
But no theology should require society to abandon an endangered child.
The state has a compelling interest in protecting children from sexual abuse. Children cannot remove themselves from abusive homes. They may lack the language, power, transportation, money, or trusted adult necessary to seek help. They often depend entirely on adults who recognize danger and take action.
That is why mandatory-reporting laws exist.
They do not require clergy to determine whether abuse occurred beyond all doubt. They require a report when the legal threshold—usually reasonable suspicion or reasonable belief—is met. Trained authorities then investigate.
Reporting is not a conviction.
It is not an attack on religion.
It’s the beginning of a safety assessment.
The choice should not be framed as protecting confession or protecting children. Legislatures can preserve legitimate spiritual confidentiality while requiring action when a communication reveals ongoing abuse, future danger, or an identifiable child who needs protection.
Lawmakers Must Close Clergy Reporting Loopholes
The Arizona legislature wrote the exemption that the court applied. The legislature can change it.
Lawmakers should consider reforms that:
- Require reports of current or threatened child abuse, even when clergy first learn of it through confession.
- Limit any privilege to genuinely penitential communications rather than administrative meetings, disciplinary councils, institutional investigations, or communications involving multiple participants.
- Clarify that internal dissemination can defeat confidentiality, especially when information travels through legal, risk-management, insurance, personnel, or institutional channels.
- Separate spiritual confidentiality from institutional knowledge. A religious organization should not automatically inherit a personal clergy privilege when it uses information to make administrative or disciplinary decisions.
- Preserve civil causes of action when an institution’s failure to report or protect allows additional abuse.
- Prohibit retaliation against clergy members who make good-faith reports.
- Require child-safety training for clergy and lay religious leaders, including clear direction that internal hotlines do not replace reports to public authorities.
- Mandate documentation and external review when leaders decide that a disclosure falls within a statutory exemption.
- Make clear that the privilege belongs to the person seeking spiritual counsel, not automatically to the institution seeking protection from liability.
- Reject any exemption when a child faces an ongoing or foreseeable threat.
A statute that allows an adult’s confession to outweigh a child’s safety has its priorities backward.
What Religious Institutions Should Do Now
Religious organizations should not wait for lawmakers or courts.
They should adopt a universal policy requiring leaders to report suspected child abuse whenever the law permits a report even if a narrow statutory exemption means the report is not technically mandatory.
Every institution should:
- Place child safety above reputation management;
- Require reports directly to law enforcement or child-protection authorities;
- Prohibit leaders from relying exclusively on internal legal or abuse hotlines;
- Remove alleged offenders from access to children pending a safety review;
- Preserve records and electronic evidence;
- Notify insurers without allowing insurance concerns to dictate child-safety decisions;
- Provide independent advocates for affected children;
- Train leaders on grooming and institutional betrayal;
- Audit prior abuse reports; and
- Cooperate fully with outside investigations.
An institution that claims to care about children should willingly exceed the legal minimum.
How Civil Lawsuits Promote Child Protection
Civil lawsuits do more than compensate individual survivors.
They can expose patterns that private institutions have kept hidden. They can uncover prior complaints, internal policies, legal advice, transfers, confidential settlements, disciplinary records, and decisions that allowed offenders to retain access to children.
Civil litigation can also force institutions to answer questions they avoided for years:
- Who knew?
- When did they know?
- What did they do?
- Whom did they warn?
- Why did they remain silent?
- Did they protect the child or the institution?
Financial accountability matters because institutions respond to incentives. When secrecy carries no meaningful consequence, secrecy can become policy. When preventable harm creates legal and financial liability, institutions have stronger incentives to adopt safer practices.
No verdict can erase childhood sexual abuse. However, civil accountability can provide resources for treatment, recognize the magnitude of the harm, and push institutions to prevent the next child from suffering.
How Andreozzi + Foote Helps Survivors of Clergy and Institutional Abuse
Andreozzi + Foote represents survivors of sexual abuse in civil cases against perpetrators and the institutions that enabled, concealed, or failed to prevent abuse.
Our attorneys focus exclusively on sexual abuse litigation. We understand that clergy-abuse cases often involve complex questions concerning religious organizations, mandatory reporting, institutional duties, statutes of limitation, privileges, internal records, and multistate operations.
We investigate far beyond the individual offender.
Depending on the evidence and applicable law, our work may include:
- Identifying every institution and individual that had notice of the danger;
- Examining whether information came from sources outside a privileged confession;
- Investigating prior complaints and other potential victims;
- Obtaining institutional policies and disciplinary records;
- Evaluating negligent hiring, supervision, retention, and failure-to-warn claims;
- Determining whether concealment affected the statute of limitations;
- Analyzing institutional representations made to families;
- Retaining experts on child protection, institutional practices, and trauma; and
- Pursuing compensation for therapy, emotional distress, lost opportunities, and other lifelong harm.
The Arizona ruling may narrow one pathway to civil accountability. It does not mean every survivor of clergy abuse lacks a claim.
Facts matter. State law matters. The source of the institution’s knowledge matters. The institution’s relationship with the perpetrator and survivor matters. Actions taken outside the confessional setting matter.
Survivors deserve a careful legal analysis—not a reflexive conclusion that religious privilege ends the inquiry.
Frequently Asked Questions About the Arizona Clergy Reporting Ruling
Did the Arizona Supreme Court rule that clergy can never be sued for failing to protect a child?
No. The court ruled in favor of the church defendants based on Arizona’s specific clergy-reporting exemption, the record in this case, and First Amendment limits on judicial examination of religious doctrine.
Religious institutions do not have complete immunity from generally applicable civil laws. Other claims may proceed when courts can apply neutral legal principles without interpreting doctrine.
Are Arizona clergy mandated reporters?
Arizona’s reporting statute generally includes clergy within its reporting framework. However, it permits clergy to withhold a confession or confidential religious communication when the clergy member determines that confidentiality is reasonable and necessary within the concepts of the religion.
The precise application of the exemption depends on the communication and surrounding facts.
Does clergy privilege protect personal observations of child abuse?
Not necessarily. Arizona’s law states that the clergy exemption applies to the confession or confidential communication, not to personal observations a clergy member may otherwise make of a child.
Information from witnesses, records, a child’s direct disclosure, physical observations, or secular institutional channels may receive different treatment.
Can clergy voluntarily report abuse disclosed during confession?
The Arizona provision says qualifying clergy “may” withhold the communication. The statute does not state that every qualifying disclosure must remain unreported.
Whether a separate evidentiary privilege, church rule, or other law affects disclosure requires an individualized legal analysis.
Can survivors still sue the individual perpetrator?
Potentially, yes. Claims against the perpetrator are legally distinct from claims against an institution. However, statutes of limitation, the perpetrator’s death, available assets, and other state-specific rules may affect the case.
Can a survivor sue a church for negligent supervision?
Potentially. A negligent-supervision claim may depend on whether the institution exercised authority over the offender, knew or should have known about a danger, provided access to children, or failed to follow reasonable safety practices.
The clergy exemption may affect certain evidence but does not automatically eliminate every institutional-liability theory.
Does this Arizona decision apply in other states?
The ruling binds Arizona courts interpreting Arizona law. It may influence arguments elsewhere, but every state has its own reporting statutes, clergy privileges, civil-liability rules, and statutes of limitation.
What should someone do if a child may currently be in danger?
Call 911 if the danger is immediate. Otherwise, contact the appropriate state child-protection agency or law-enforcement authority.
Do not rely solely on an institution’s internal reporting system when a child may face abuse.
Speaking With a Clergy Sexual Abuse Lawyer About Your Rights
The Arizona Supreme Court’s decision is a devastating reminder that the law does not always place children first.
Survivors should not assume that this ruling eliminates every possible civil claim. Cases involving religious institutions require a detailed investigation into what the institution knew, how it learned the information, what duties it assumed, who had access to the child, and whether the institution’s actions allowed abuse to continue.
Andreozzi + Foote represents survivors of clergy and institutional sexual abuse nationwide. Our trauma-informed attorneys provide free and confidential consultations so survivors and families can understand their legal options.
Call (866) 858-3790 or email info@vca.law.
There is no obligation to move forward simply because you ask questions about your rights.
This blog provides general information and does not constitute legal advice. Reading it does not create an attorney-client relationship. Laws and filing deadlines vary by jurisdiction, and every case requires an individualized legal analysis.