The Arizona Supreme Court ruled that religious leaders are not required to report child sexual abuse to authorities if the information is disclosed during a religious confession, a decision that protects the First Amendment rights of clergy to determine their own religious doctrines. The unanimous ruling, issued on Thursday, prevents courts from intervening in how religious institutions define a 'confession' or 'confidential communication.'
Judicial Deference to Doctrine
The ruling in the case of Doe v. The Corporation of the President of The Church of Jesus Christ of Latter-day Saints resolves a long-running legal battle involving the disclosure of sexual abuse. The litigation began after three children filed a lawsuit in 2020, alleging that the Church of Jesus Christ of Latter-day Saints and two bishops failed to report years of sexual abuse committed by their parents.
Under Arizona law, clergy are not mandated reporters, and suspected child abuse is not exempted from reporting requirements, even if the abuse is ongoing. However, the Supreme Court clarified that religious leaders are exempt from these duties if the information is received through a confidential religious communication. The court's decision overturns a previous ruling by an appeals court that had suggested a jury should determine if the privilege was waived because the abuse was discussed during a disciplinary hearing and in the presence of a spouse.
In the court's 23-page opinion, Vice Chief Justice John R. Lopez IV wrote that the First Amendment prohibits judges from inquiring into a clergy member's application of religious doctrine to determine if reporting should be withheld. Lopez noted that while religious institutions do not enjoy general immunity from secular laws, the court cannot evaluate whether a bishop followed his own church's internal handbook or religious rules when deciding not to report abuse.
"The First Amendment... requires courts to exercise substantial deference to a religious institution's own doctrinal conception of confession or confidential communication," Lopez wrote. He added that further inquiry into whether specific admissions constitute a confession is
Background on the Adams Case
The case originated from the actions of Paul Adams, a Customs and Border Patrol officer in Bisbee who was arrested in 2017 after videos of him abusing his children appeared online. Court filings revealed that Adams had confessed his crimes to a bishop in 2010 and again during a formal disciplinary hearing in 2011.
Despite these confessions, the abuse continued for years. A 2022 investigation by the Associated Press reported that a church-operated help line had advised a bishop not to contact authorities or law enforcement regarding the abuse. Adams committed suicide while in custody, and his wife, Leizza Adams, received a 30-month sentence in 2018 after pleading no contest to two felony charges of child abuse.
Church Response to Ruling
The LDS Church welcomed the unanimous ruling, stating that the decision affirms that religious protections must be respected alongside society's commitment to protecting the vulnerable. The church noted that while the abuse at the center of the case was reprehensible, it has always condemned such actions and devotes significant resources to preventing abuse and encouraging reporting through safeguarding efforts.
Advocacy Group Criticism
Advocates for abuse survivors expressed deep disappointment with the decision. Angela Walker, the executive director of the Survivors Network of those Abused by Priests (SNAP), stated on Aug. 4, 2026, that the ruling creates a "confessional loophole" that allows predators to escape justice.
Walker argued that the safety of children should take precedence over church doctrine and urged Arizona lawmakers to reform the law to require mandatory reporting by all religious leaders, similar to laws in other states. She noted that in the Adams case, multiple denominations appeared to prioritize protecting the church over protecting the children.
National Context
The Supreme Court's decision follows similar legislative tensions in other states. For example, a 2025 law in Washington state intended to compel clergy to report sexual abuse was withdrawn in October after legal challenges from the Catholic Church.
