Arizona Supreme Court Protects the 'Seal of the Confessional' — Clergy Need Not Report Abuse Disclosed In Confession

The Arizona Supreme Court has unanimously ruled that clergy who learn about child abuse during religious confession or other confidential religious communications are not required to report those disclosures to civil authorities, reaffirming legal protections for the "seal of the confessional." The decision resolves a high-profile lawsuit that accused the Church of Jesus Christ of Latter-day Saints (LDS) and two local bishops of remaining silent after learning of sexual abuse of children.

The lawsuit, filed in 2020 by the children of Paul and Leizza Adams of Cochise County, alleged the couple abused the children over several years. Court records indicate Paul Adams admitted the abuse to a bishop during a 2011 confession, and the matter was later discussed at a formal church disciplinary hearing in 2012. An Associated Press investigation published in 2022 reported that church officials followed internal procedures and that a second bishop sought guidance from an internal helpline and was advised not to contact police or child-protective authorities.

The abuse continued until video evidence surfaced in New Zealand in 2017, prompting the arrests of Paul and Leizza Adams. Paul Adams died by suicide while jailed awaiting trial; Leizza Adams pleaded no contest to two felony child-abuse charges and received a 30-month sentence in 2018.

Vice-Chief Justice John Lopez wrote the court's 23-page opinion, saying the First Amendment bars courts and juries from probing religious doctrine or internal religious motivations when evaluating a clergy member's decision not to report disclosures made in confession or similarly confidential religious contexts. Lopez emphasized that this protection is not absolute: if a court finds evidence was procured through fraud or collusion for secular purposes, religious protections can be lost. The court found no evidence of fraud or collusion in this case.

The LDS Church welcomed the ruling, saying Arizona law recognizes the confidential nature of religious confession and that the decision reaffirms those religious protections alongside society's commitment to protect vulnerable people. The church reiterated its condemnation of abuse and said it devotes significant resources to prevention, victim support and safeguarding efforts worldwide.

Legal Context and Broader Implications

Legal experts say the ruling highlights the tension between mandated-reporting laws designed to protect children and constitutional protections for religious practice. The decision echoes a related national debate: a 2025 Washington state proposal that would have required clergy to report sexual abuse was permanently withdrawn after legal challenges by the Catholic Church.

Timeline

• 2011 — Paul Adams reportedly confessed to a bishop.
• 2012 — The issue was discussed at a church disciplinary hearing.
• 2017 — Video evidence surfaced in New Zealand, leading to arrests.
• 2018 — Leizza Adams received a 30-month sentence after pleading no contest.
• 2020 — Children filed the civil lawsuit against the LDS Church and two bishops.
• 2022 — Associated Press published an investigation into the church's internal handling of the reports.
• 2026 — Arizona Supreme Court issued a unanimous 23-page opinion upholding clergy confidentiality.

Resources

If you or someone you know needs help, contact local child-protection authorities immediately. Additional hotlines and support services include:

• United States: Childhelp National Child Abuse Hotline — 800-422-4453 (call or text), childhelp.org.
• Adult Survivors (U.S.): ASCASupport.org.
• United Kingdom: NSPCC — Children: 0800 1111; Adults concerned about a child: 0808 800 5000. Napac (adult survivors): 0808 801 0331.
• Australia: Kids Helpline — 1800 55 1800; Bravehearts — 1800 272 831; Blue Knot Foundation (adult survivors) — 1300 657 380.
• Global: Child Helplines International — childhelplines.org.