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Arizona Supreme Court Rules Churches Decide What Counts as Confession

Liberty Desk · laws, courts, and the public square·July 2026

The Arizona Supreme Court ruled unanimously on July 30 that it is up to a church, not a judge or jury, to decide what counts as a confidential confession under state law, shielding clergy from Arizona's mandatory child abuse reporting requirement when abuse is disclosed in that context. The case arose from a lawsuit by three children of Paul Adams against leaders of The Church of Jesus Christ of Latter-day Saints, who argued the church should have reported Adams's admissions of abuse. Vice Chief Justice John Lopez wrote that the First Amendment generally bars courts from second-guessing a clergy member's application of religious doctrine, absent fraud or collusion.

Clergy in Arizona still must report abuse they learn about outside a confidential religious confession, and the court said judges may look more closely at the facts in rare cases involving fraud or collusion to dodge legal responsibility. The ruling sends the underlying case back to a lower court and reverses a 2025 appeals court decision that had gone the other way.

This brief is based on reporting from Religion News Service.
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