The Arizona Supreme Court has ruled that clergy members who learn of child abuse during religious confession are not required to report it, upholding what church leaders call the “seal of the confessional.” This unanimous decision, issued on Monday, August 3rd, 2026, concludes a long-running case involving three children who were sexually abused by their parents and who sued the Church of Jesus Christ of Latter-day Saints (LDS) and two bishops aware of the abuse but who remained silent.

The case centered on a 2020 lawsuit filed by the children of Paul and Leizza Adams, residents of Cochise County, Arizona, who reported years of abuse. Court filings revealed that Paul Adams admitted to his crimes during a confession to a bishop in 2011. Despite this, the abuse continued until 2017, when Paul Adams and his wife were arrested after a video documenting some of the abuse surfaced in New Zealand. Paul Adams later took his own life in jail while awaiting trial.

In the 23-page ruling, Vice-Chief Justice John Lopez emphasized that the First Amendment of the U.S. Constitution, which protects religious freedom, prevents courts and juries from evaluating religious doctrine when considering a clergy member’s decision not to report abuse.

The LDS Church welcomed the ruling, which exempts clergy from being mandated reporters if they learn of abuse through confession or other confidential methods. The church stated, “The abuse of a child or any person is a tragic betrayal of trust. The abuse at the center of this case was reprehensible, and the church has always condemned it.”

This ruling contrasts with a 2025 Washington state law that briefly required clergy to report sexual abuse but was withdrawn after legal challenges from the Catholic Church.

Sources