Arizona Supreme Court Ruling on the Clergy-Confession Reporting Exemption

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.