The Arizona Supreme Court ruled unanimously that clergy members who learn of child abuse during a religious confession are not required to report it to authorities, holding that the First Amendment bars courts from second-guessing religious doctrine on what counts as a confession. The 23-page opinion, written 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 traces back to a 2020 lawsuit filed by the children of Paul and Leizza Adams, who were sexually abused by their parents over several years. Paul Adams confessed his crimes to a bishop in the Church of Jesus Christ of Latter-day Saints in 2011. The next year, the abuse came up at a formal disciplinary hearing led by a different bishop. Neither bishop reported the abuse to police or child-protection authorities. The Adamses were arrested in 2017 after a video they had 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 LDS Church and the two bishops who had known about the crimes. A lower appeals court had held that the confession and disciplinary hearing discussions might not have been truly confidential, which could mean the clergy exemption did not apply. The Supreme Court reversed that reasoning, ruling that churches, not judges, get to define what constitutes a confession for the purpose of clergy reporting duties (Arizona Mirror).

Under Arizona law, clergy members are not classified as mandated reporters — professionals legally required to report suspected child abuse to authorities — and that exemption holds 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 broadening of clergy privileges (Arizona Courts).

Vice-Chief Justice Lopez wrote that the First Amendment prevents courts and juries from evaluating religious doctrine when weighing a clergy member's reasons for not reporting abuse. He cited a 2020 U.S. Supreme Court ruling (case 19-267) to stress that the decision does not grant religious institutions blanket immunity from secular laws. The opinion drew a line between respecting church doctrine on confession and exempting churches from legal obligations more broadly (The Guardian).

The case drew substantial amicus participation — that is, legal briefs filed by outside parties with an interest in the outcome. 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 a Ninth Circuit ruling in the Father Mockaitis case, in which the court 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, which protects religious practice from government interference. Several states maintain clergy-penitent privileges — legal protections that keep confessional communications confidential — 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 meet the same First Amendment reasoning the Arizona court applied. 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.