On 30 July 2026 the Arizona Supreme Court unanimously ruled, in Doe v. Corporation of the President of The Church of Jesus Christ of Latter-day Saints, that clergy in Arizona have no legal duty to report a congregation member's abuse of a minor when it is disclosed through confession or another confidential religious communication, and that it is the church's own doctrine, not an independent judicial assessment, that defines what counts as such a communication. The case began as a 2020 Cochise County lawsuit brought by the children of a church member who, during a 2011 confession, told his bishop he had sexually abused his five-year-old daughter, one of the plaintiffs; the member repeated the disclosure in a second confession and again at a church disciplinary proceeding. The Cochise County Superior Court dismissed the reporting claim against the church and its two local officials in 2023, finding no legal obligation to report abuse disclosed under those circumstances; the Arizona Supreme Court affirmed that dismissal unanimously, with the opinion authored by Vice Chief Justice John R. Lopez IV. It was not the church that ended the abuse: an international law enforcement investigation traced material back to the member in 2017. The plaintiffs' attorney said she intends to seek review from the United States Supreme Court.
Facts
Inquiry Profile
Kind of Record Jurisdiction Commissioned ByArizona Supreme Court, on appeal from the Cochise County Superior Court 1 Publication Year Period Covered, FromThe lawsuit's own period: filed in Cochise County in 2020, decided by the Arizona Supreme Court in 2026. The underlying confession dates to 2011, already recorded on this axis by the separate 2022 AP investigation, entity 53783. Period Covered, To Documented Findings
Key FindingThe court held that Arizona's clergy-reporting exemption turns on the church's own doctrine of what counts as a confidential religious communication, not on a judge's independent factual assessment, so a church's internal characterization of a disclosure as confession-like can place it outside the mandatory reporting law entirely. 2 Key FindingThe ruling was unanimous and ends this particular reporting-duty claim in Arizona state courts; the plaintiffs' attorney, who said she had been in the legal fight for seven years, stated an intention to seek review from the United States Supreme Court. 1 Connections
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Source High Court Says Churches, Not Judges, Define a "Confession" When It Comes to Reporting Child Abuse
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Source Church Leaders Not Bound to Report Sexual Abuse Confessions, Arizona Supreme Court Rules
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Sources
1. Church Leaders Not Bound to Report Sexual Abuse Confessions, Arizona Supreme Court Rules
2. High Court Says Churches, Not Judges, Define a "Confession" When It Comes to Reporting Child Abuse
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