The Arizona Supreme Court ruled unanimously that clergy are not required to report a congregation member's abuse of a minor if they learn of it through confession or another confidential religious communication, and if withholding it aligns with their faith's doctrine.
The case originated in Cochise County, stemming from a 2020 lawsuit against The Church of Jesus Christ of Latter-day Saints and two of its bishops, John Herrod and Robert "Kim" Mauzy.
Court records show Paul Adams confessed to abusing his children during a 2011 confession with Herrod, again in a second confession with Herrod and his wife, Leizza, and a third time during a church disciplinary proceeding with Mauzy. Mauzy excommunicated Adams in 2013.
Paul and Leizza Adams were indicted in 2017 on charges related to the abuse. Leizza pleaded guilty and was sentenced to two and a half years in prison. Paul confessed to law enforcement but died by suicide in jail before trial.
The three children sued the church and bishops, alleging they violated Arizona's mandatory reporting law.
A Cochise County Superior Court judge dismissed the case in 2023, finding the bishops were not required to report the abuse under the law. An appeals court reversed that ruling, but the state Supreme Court sided with the trial court, reinstating the dismissal.
The court cited First Amendment protections, stating judges and juries cannot question clergy members' interpretation of their own religious doctrine.
Vice Chief Justice John R. Lopez IV wrote that the reporting statute and "bedrock First Amendment principles compel our decision in favor of the Church Defendants."
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