Arizona’s supreme court has ruled that clergy members who learn of child abuse during religious confession are not required to report it, in a decision that protects what church leaders describe as the “seal of the confessional”. The ruling ends a long-running case brought by three children who said they were sexually abused by their parents, and who sued the Church of Jesus Christ of Latter-day Saints, also known as the LDS church, along with two bishops who learned of the crimes but did not alert authorities.
What did the Arizona supreme court decide?
The Arizona supreme court said clergy members are exempt as “mandated reporters” when they learn of abuse of minors in the confession booth or through other “confidential” methods. The decision was issued on Thursday and was welcomed by the LDS church, which said Arizona law recognizes the confidential nature of religious confession.
“The abuse of a child or any person is a tragic betrayal of trust,” it said. “The abuse at the center of this case was reprehensible, and the church has always condemned it. The church is deeply concerned for these children and for all who have suffered abuse.
“The church devotes significant resources to preventing abuse, helping victims, and encouraging reporting through safeguarding efforts around the world. The church has always been willing to help the victims in this case and that continues to be true.
“Arizona law also recognizes the confidential nature of religious confession. [The] decision affirms that these religious protections are to be respected alongside society’s shared commitment to protect the vulnerable.”
How did the abuse case begin?
The case centered on a 2020 lawsuit filed by the children of Paul and Leizza Adams, who said they were abused by the Cochise county couple over a number of years. Court filings said Paul Adams, who later took his own life in jail while awaiting trial, admitted his crimes to a bishop during confession in 2011. The filings also said the abuse was discussed at a formal disciplinary hearing led by a separate bishop the following year.
A 2022 Associated Press report said the church followed its own policy of keeping the information to itself. According to the AP, the second bishop called an internal church helpline for advice but was told not to contact police or child welfare officials.
The abuse continued, and Adams and his wife were not arrested until 2017, after a video they made of some of the abuse was discovered in New Zealand. Adams died while awaiting trial, and Leizza Adams was sentenced in 2018 to 30 months after pleading no contest to two felony charges of child abuse.
Why did the court overturn the appeals ruling?
The Arizona supreme court overturned a state appeals court ruling that had favored the children on the basis that the confession and disciplinary hearing discussions might not have been truly confidential. In the 23-page ruling, vice-chief justice John Lopez said the First Amendment to the US constitution, which addresses religious freedom, stopped courts and juries from judging religious doctrine when evaluating a clergy member’s decision not to report abuse.
“Our decision ‘does not mean that religious institutions enjoy a general immunity from secular laws’,”
he wrote, citing a 2020 US supreme court ruling about the church’s right to decide matters of government, faith and doctrine “free of government interference”. Lopez also wrote:
“If a court finds a religious institution submitted evidence procured through ‘fraud’ or ‘collusion’ for secular purposes, it will lose the religion clauses’ protection”
There was no evidence that the LDS church had done so, Lopez said.
How does this compare with other clergy-reporting laws?
The case has parallels with a short-lived 2025 law in Washington state that would have required clergy members to report sexual abuse. That proposal was withdrawn in October after legal action by the Catholic church. The Arizona ruling is therefore likely to be closely watched by religious institutions and advocates for abuse reporting in other states.
Where can people get help?
In the US, people can call or text the abuse hotline on 800-422-4453 or visit for more resources and to report child abuse or DM for help. For adult survivors of child abuse, help is available at . In the UK, the offers support to children on 0800 1111, and adults concerned about a child on 0808 800 5000. The National Association for People Abused in Childhood () offers support for adult survivors on 0808 801 0331. In Australia, children, young adults, parents and teachers can contact the Kids Helpline on 1800 55 1800, or on 1800 272 831, and adult survivors can contact on 1300 657 380. Other sources of help can be found at.
Key Facts
- Arizona’s supreme court ruled clergy need not report abuse learned in religious confession.
- The case involved three children who sued the LDS church and two bishops over sexual abuse by their parents.
- Paul Adams admitted crimes to a bishop in 2011, and the abuse was later discussed at a 2012 disciplinary hearing.
- Adams and his wife were arrested in 2017; Adams died awaiting trial and Leizza Adams received 30 months in 2018.
- The decision cited First Amendment protections and found no evidence the LDS church acted through “fraud” or “collusion”.
