The Mormon Church Was Sued for Reporting Abuse — and for Not Reporting It

Two states. Two lawsuits. Opposite accusations. What the clergy-penitent privilege actually is, what the Church's handbook actually says about breaking confidentiality — and what a unanimous Arizona Supreme Court ruling just changed.

By Todd Noall · Mormonism Explained · Published August 11, 2026

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KEY FACTS — THE 60-SECOND VERSION

In Arizona, the Church was sued for not reporting a member's confession — in a state whose law privileged that confession. On July 30, 2026, the Arizona Supreme Court ruled unanimously that its clergy's determination of what is confidential is not for courts to second-guess; the case is on remand.
In Oregon, the Church was sued for reporting a member's confession — a $9.54 million suit filed in 2020 by the member's wife, in a state whose law required the report. He is serving 15 years.
The Church's General Handbook (§32.4.4) authorizes breaking confessional confidentiality when "necessary to prevent life-threatening harm or serious injury" — and instructs leaders to obey reporting laws even over doctrine (§32.4.5). Latter-day Saints do not practice the Catholic absolute seal.
Peer-reviewed studies found states that mandate clergy reporting had lower confirmed abuse-report rates — and perpetrator self-referrals to a Johns Hopkins clinic collapsed to nearly zero once reporting was mandated there.
The reform debate is real and two-sided; this article presents the strongest case for both. What both lawsuits prove is narrower: the Church follows state law — and gets sued either way.

Two lawsuits that cannot both be right

Here are two true stories about the same church, five hundred miles apart.

In Arizona, a member named Paul Adams confessed to his bishop that he had abused his daughter. Arizona law makes clergy mandatory reporters — but exempts confessions. The bishop, advised the confession was privileged, did not call police; he pressed Adams to self-report, brought Adams's wife into a second confession so she would know, counseled him to move out and never be alone with the children, and followed up. The abuse continued anyway — the wife assured the bishop it wasn't — until federal agents arrested Adams in 2017. His children sued the Church for not reporting. VERIFIED

In Oregon, a member named Timothy Johnson confessed to his clergy in 2017 that he had sexually abused a minor. Oregon law makes clergy mandatory reporters — with a much narrower shield. The confession was reported to authorities. Johnson pleaded guilty and is serving 15 years. In January 2020, his wife, Kristine Johnson, sued the Church for $9.54 million — for reporting. Her theory: the Church violated its own doctrine of confidentiality. A church spokesman answered that "leaders and members should fulfill all legal obligations to report abuse." VERIFIED

Sued in Arizona for staying silent. Sued in Oregon for speaking up. In both states, the Church followed that state's law.

You cannot understand the abuse-lawsuit debate — or last month's Arizona Supreme Court ruling — without understanding the legal machinery both cases turn on. So let's open it up.

What the privilege actually is

The clergy-penitent privilege is older than the republic's railroads. American courts have recognized it since People v. Phillips in 1813 — a case in which, notably, a priest had already persuaded a thief to return what he stole before refusing to name him. Every state protects clergy communications in some form. It belongs to a family of confidences the law deliberately shields — attorney-client, psychotherapist-patient, doctor-patient — on a theory the U.S. Supreme Court has endorsed for all of them: some conversations only happen if they are safe, and society is better off when they happen.

Two separate legal ideas get mashed together in every viral post about this subject, and the 2026 Arizona ruling just made the distinction load-bearing. The privilege is testimonial: it governs whether clergy can be forced to testify. The reporting exemption is statutory: it governs whether clergy must call authorities. Thirty-three states maintain some confessional exemption in their reporting laws; a handful require clergy to report even confessions; in the rest, clergy aren't mandatory reporters at all. Our 50-state breakdown maps it. The rule that decides whether a bishop must report is the state's — not the Church's.

What the Handbook actually says

Critics describe Latter-day Saint confession as a vault no key opens. The Church's own General Handbook — public, online, searchable — says otherwise, in five numbered circumstances and one unmistakable sentence. Section 32.4.4 permits a bishop to share confidential information: in consultation with senior leaders, when a member moves, with the member's permission, in a membership council, and when required by law. Then comes the ceiling: confidentiality may be broken when "necessary to prevent life-threatening harm or serious injury." The handbook's reasoning is one sentence long and it is the whole ballgame: "the duty to protect others is more important than the duty of confidentiality." VERIFIED — PUBLISHED DOCTRINE

Section 32.4.5 instructs leaders to obey reporting laws even where law and doctrine collide, supported by a 24/7 help line staffed to keep them legal in all fifty states — a system we've investigated separately. And §38.6.2.7 tells bishops to urge abusers to report themselves to law enforcement. This is a different architecture from the Catholic sacramental seal, which admits no exception — not consent, not law, not imminent harm — and whose priests have accepted jail over breach. Latter-day Saint doctrine is confidentiality with a ceiling. The critics' vault does not appear in the documents.

Oregon: the ceiling, operating

Doctrine on paper is cheap; the Johnson case is the receipt. Oregon's reporting law reached the confession, the confession was reported, and the man went to prison. The suit that followed attacked the Church from the direction no critic acknowledges exists: for insufficient secrecy. (One detail from the coverage captures the legal thicket perfectly — the clergyman who reported was a pharmacist by day, making him a mandatory reporter twice over.) We could not locate a published resolution of the civil suit, and we say so plainly rather than guess. But the fact that decides this article's question isn't the suit's outcome — it's that the report happened, exactly as the handbook and the state required. DOCKET STATUS: VERIFYING

One more thing, said carefully: the abuse in Oregon was real, a child was harmed, and nothing in this analysis treats that as a debating point. The suit's plaintiff was not the victim. Our subject is the legal machinery, not anyone's grief.

Arizona: who decides what a confession is

Now the ruling that put this subject back in the headlines. The Adams children's lawsuit — the hardest case in this entire literature, which we examine unflinchingly in our lawsuits investigation — had been dismissed in 2023, partially revived by an appeals court in 2025 on the theory that Adams waived the privilege by repeating his confession before his wife and a disciplinary council. On July 30, 2026, the Arizona Supreme Court reversed, unanimously.

The court held two things. First, the clergy-penitent privilege is a testimonial privilege — it answers who can be compelled to testify, and says nothing about the reporting statute, so waiver analysis was the wrong tool. Second, the reporting statute's exemption turns on the clergy's own reasonable religious determination of what constitutes a confidential communication — and under the church-autonomy doctrine, civil courts cannot second-guess that religious judgment. VERIFIED

Be precise about what that means, because both celebration and outrage are outrunning the text. It is not a merits verdict; the children's claims return to the lower courts on remand. It is a who decides ruling: in Arizona, the boundary of a confession is drawn by the faith's sincere framework, not reconstructed by a jury afterward. Critics call that churches grading their own homework. Supporters call it the First Amendment doing exactly its job — and note that a Washington law drawn the other way was declared unconstitutional in 2025, with a federal court entering a permanent injunction. Both descriptions are about the same line: the one between civil courts and religious doctrine. The place to move the reporting rule, if a state wants it moved, is the legislature.

Would abolishing the privilege save children?

This is the empirical question underneath every op-ed, and it has actual research. A 2014 peer-reviewed study comparing states found that where clergy were required to report, confirmed maltreatment report rates were lower — "lower report rates that were statistically significant for confirmed reports" — and the 2016 follow-up found that changing mandates didn't improve identification. The mechanism isn't mysterious. After Maryland required psychiatrists to report patient disclosures in 1989, perpetrator self-referrals to Johns Hopkins's sexual-disorders clinic — 73 men in the prior decade, each an intervention opportunity — dropped to nearly zero. Stop It Now!'s anonymous WhatsOK line for young people reports two-thirds of its youth contacts had abused or feared abusing a child; they called because anonymity was promised. Abuse happens behind doors that open only from the inside — a framing we borrow from the fullest legal treatment of this question, a 2026 response paper by Paul G. Cassell, University of Utah law professor and former federal judge. (Disclosure, because we'd demand it of others: Cassell's paper credits Kirton McConkie attorneys — the Church's outside counsel — for information about the help line. The studies above are independent and peer-reviewed.) VERIFIED AS PUBLISHED RESEARCH

One legal commentator's two-decade survey landed harder than any statistic: he did "not know of a single child abuse case… that would have resolved differently" without the privilege.

The honest case for reform — and its honest cost

Steelman the reformers, because their position is sincere and its emotional core is legitimate: a confessed abuser walked out of a church office and no phone rang. Washington's legislature found that intolerable. Utah's has debated it. If even one report stops one abuser, the argument runs, the privilege is priced in children. And reformers are right that the privilege is not cost-free in the individual case — Arizona is the proof.

But the strongest reform argument has to face two facts this article has laid on the table. First, the empirical record suggests mandates don't produce more confirmed reports — they produce fewer confessions, and the doors stay shut. Second — less discussed and more uncomfortable — mandatory reporting also binds victims. Most survivors first disclose decades after the abuse, on their own terms; trauma researchers describe compelled reporting of a victim's confidential disclosure as a second betrayal, this time by the confidant. A rule written to trap perpetrators' confessions also tells a fifty-year-old survivor that the pastor she finally trusts is a police informant. Any honest reform has to price that in too. The debate is real. It should be had with evidence, in statehouses — not with a vault that doesn't exist.

THE VERDICT

The claim that the Mormon church "never reports and hides behind privilege" is contradicted by the record in both directions at once. The Church's written doctrine is confidentiality with a ceiling — breakable to prevent serious harm, subordinate to reporting law everywhere reporting law reaches. In Oregon it reported, and was sued for it. In Arizona it honored a privilege the state itself wrote, and was sued for that. The 2026 Arizona Supreme Court ruling settled who draws the boundary of a confession; it did not settle the policy debate, which belongs to legislatures and should be argued with the empirical record on the table. Whatever the right answer in the statehouse, one conclusion is now proven twice over, from opposite directions: the Church follows state law — and the law, not the Church, decides what must be reported.

FAQ

What is the clergy-penitent privilege?

A rule, recognized in American law for over two centuries and in some form in all 50 states, that protects confidential communications between a person and their clergy — most commonly confessions — from compelled disclosure. The 2026 Arizona Supreme Court ruling clarified it is a testimonial privilege, distinct from any exemption in a state's mandatory-reporting statute.

Does the Mormon church report abuse confessed to bishops?

Where state law requires clergy to report, the Church instructs leaders to obey the law — General Handbook 32.4.5 — and in Oregon it was sued by a member's wife in 2020 precisely because clergy reported her husband's confession. Where state law privileges confessions, as in Arizona, leaders may honor confidentiality, but the handbook (32.4.4) authorizes breaking it when necessary to prevent life-threatening harm or serious injury.

What did the Arizona Supreme Court rule in 2026?

On July 30, 2026, it ruled unanimously that the clergy-penitent privilege is a testimonial privilege separate from the reporting statute, and that the reporting exemption turns on the clergy's own religious determination of what is a confidential communication, which courts cannot second-guess. It reversed a 2025 appeals ruling and remanded the Adams case. It is a ruling about who decides, not a merits verdict.

Would abolishing the privilege protect children?

The peer-reviewed evidence points the other way: states mandating clergy reports showed statistically significant lower confirmed-report rates (Vandervort & Palusci 2014; follow-up 2016), and perpetrator self-referrals to a Johns Hopkins clinic dropped to nearly zero after Maryland mandated psychiatrist reporting. Reform advocates counter that any confession left unreported is intolerable — a sincere position this article presents. The empirical question is which regime produces fewer victims.

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SOURCES

Arizona Supreme Court ruling coverage: Religion News Service (Aug. 4, 2026); AZFamily, Arizona Mirror (Jul. 30, 2026) · CNN, TIME, Seattle Times/Washington Post on Johnson v. Church (Jan. 2020) · General Handbook §§32.4.1, 32.4.4, 32.4.5, 38.6.2.7, churchofjesuschrist.org · Etienne v. Ferguson, 791 F. Supp. 3d 1226 (W.D. Wash. 2025); stipulated permanent injunction (Oct. 10, 2025) · Vandervort & Palusci, ASPSAC Advisor (2014) · Palusci, Vandervort & Lewis, Children & Youth Services Review (2016) · Frederick S. Berlin, Psychiatric Times (2014) · Stop It Now! / WhatsOK program reports · Paul G. Cassell, "The Clergy-Penitent Privilege and Preventing Child Sexual Abuse" (2026) — disclosure: paper credits Kirton McConkie attorneys for help-line information · Nathan J. Ristuccia, Mississippi Law Journal blog (2023) · People v. Phillips (N.Y. 1813) · Trammel v. United States, 445 U.S. 40 (1980); Jaffee v. Redmond, 518 U.S. 1 (1996). Facts current as of August 11, 2026; updated per our corrections policy.

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