Arizona Court Gives Churches Authority to Define Confession in Abuse Reporting Cases
The Arizona Supreme Court ruled unanimously that clergy are not required to report child abuse disclosed during religious confession, finding that the First Amendment bars courts from second-guessing how churches define their own doctrine. The case arose from a 2020 lawsuit involving leaders of The Church of Jesus Christ of Latter-day Saints.
The Arizona Supreme Court issued a unanimous ruling in August 2026 that clergy members are not legally required to report child abuse to authorities when the information is disclosed during a religious confession.
The decision, written by Vice Chief Justice John R. Lopez IV, centered on a 2020 lawsuit filed by children whose parents had sexually abused them. The victims alleged that leaders of The Church of Jesus Christ of Latter-day Saints failed to report the abuse after the perpetrator, Paul Adams, disclosed it during religious settings.
The court found that the First Amendment prohibits courts and juries from second-guessing how a religious institution interprets its own doctrine on confession. Because the LDS Church classified Adams' admissions as "confessions," the court said it could not legally challenge that determination.
Arizona's mandatory reporting statute contains an exemption for clergy who receive information via confession if they deem it "reasonable and necessary" under their faith's doctrine. The court held that this decision rests solely with the clergy and their institution.
The LDS Church welcomed the ruling, saying it affirms the confidential nature of religious confessions and that the church remains committed to preventing abuse.
Survivor advocates, including the Survivors Network of those Abused by Priests, expressed concern. They warned the ruling creates a loophole that predators may exploit to avoid legal consequences.
In a separate August 12 opinion, the court ruled that a secret recording of a Phoenix pastor admitting to sexual abuse could be used as evidence. The court distinguished that case because the conversation focused on reputation management rather than seeking spiritual absolution, avoiding First Amendment conflicts.
