The Arizona Supreme Court ruled unanimously that clergy members who learn of child abuse during religious confession are not required to report it to authorities, holding that the First Amendment bars courts from second-guessing religious doctrine on what constitutes a confession. The 23-page opinion, authored by Vice-Chief Justice John Lopez in case CV-25-0213, was issued on a Thursday and overturns a state appeals court decision that had revived claims by three children abused by their parents in Cochise County (The Guardian).

The case originated in a 2020 lawsuit filed by the children of Paul and Leizza Adams, who were subjected to sexual abuse by their parents over a number of years. Paul Adams admitted his crimes to an LDS bishop during confession in 2011. The following year, the abuse was discussed at a formal disciplinary hearing led by a separate bishop. Neither bishop reported the abuse to civil authorities. The Adamses were arrested in 2017 after a video they produced of some of the abuse surfaced in New Zealand. Leizza Adams received a 30-month sentence in 2018 after pleading no contest to two felony child abuse charges. Paul Adams died by suicide in jail while awaiting trial (The Guardian).

The children sued the Church of Jesus Christ of Latter-day Saints and the two bishops who had been aware of the crimes. The appeals court had held that the confession and disciplinary hearing discussions might not have been truly confidential, leaving open the possibility that the clergy exemption did not apply. The Supreme Court reversed that reasoning, holding that churches, not judges, define what constitutes a confession for purposes of clergy reporting obligations (Arizona Mirror).

Under Arizona law, clergy members are not classified as mandated reporters, and suspected child abuse or neglect is not exempted from that status even when the abuse is ongoing (Arizona Mirror). The court's news release, published on its website under the title "Arizona Supreme Court Clarifies Clergy Members' Duty to Report Abuse of a Minor," framed the opinion as a clarification of existing statutory boundaries rather than a substantive expansion of clergy privileges (Arizona Courts).

Vice-Chief Justice Lopez wrote that the First Amendment prevented courts and juries from assessing religious doctrine when considering a clergy member's reasons for not reporting abuse. He cited a 2020 U.S. Supreme Court ruling (case 19-267) to emphasize that the decision does not grant religious institutions general immunity from secular laws. The opinion drew a line between respecting ecclesiastical doctrine on confession and exempting churches from legal obligations writ large (The Guardian).

The case attracted substantial amicus participation. The Becket Fund for Religious Liberty filed a brief on December 16, 2025. The General Conference of Seventh-day Adventists filed its own amicus brief the same day. Three Roman Catholic dioceses — Gallup, Phoenix, and Tucson — submitted a joint amicus brief on February 24, 2026. The Catholic dioceses' brief referenced the Ninth Circuit's ruling in the Father Mockaitis case, in which the court eventually held that a recording of a confession was unconstitutional, as precedent supporting the inviolability of the confessional (Arizona Courts).

The LDS Church welcomed the ruling in a public statement (The Guardian).

The Arizona decision parallels a short-lived 2025 Washington state law that would have compelled clergy to report sexual abuse. That statute was permanently withdrawn in October 2025 following legal action by the Catholic Church (The Guardian; Deseret).

The broader context here is a recurring constitutional tension between child-protection mandates and the Free Exercise clause. Several states maintain clergy-penitent privileges that exempt confessional communications from mandatory reporting laws, but the scope of those exemptions varies considerably. The Arizona court's holding that ecclesiastical authorities, rather than secular courts, hold definitional authority over what qualifies as a confession places this state among those giving the broadest weight to institutional religious autonomy. The opinion's reliance on the First Amendment as a bar against judicial inquiry into doctrinal questions effectively narrows the factual questions a court can pose when evaluating whether a clergy member's silence fell within a protected communication.

What remains unresolved is whether legislatures can constitutionally narrow the clergy exemption by statute, as Washington attempted, or whether any such effort will be met with the same First Amendment reasoning the Arizona court deployed. The Arizona ruling does not address that question directly; it construes existing statutory language. But the opinion's reasoning, if adopted elsewhere, would pose a significant structural barrier to legislative reform aimed at closing the confessional loophole in mandated reporting regimes.