Skip to main content
Some links on this page are Amazon affiliate links. We may earn a small commission from qualifying purchases.

Arizona Supreme Court Ruling on Child Abuse Reporting

 On July 30, 2026, the Arizona Supreme Court ruled that two bishops of The Church of Jesus Christ of Latter-day Saints were not legally required to report a member’s admissions of child sexual abuse. [1]


The ruling did not dispute that the bishops knew about the abuse. It did not dispute that no report was made. It also did not dispute that the abuse continued for years before law enforcement began investigating a video that the abuser had posted online. [1] [3]


Instead, the court focused on a narrower legal question: Was it legally acceptable for the two bishops NOT to report the abuse?




What the LDS Bishops Knew


Around 2011, Paul Adams privately told Bishop John Herrod of the Bisbee Ward in Arizona that he had sexually abused one of his children. Herrod then arranged another meeting with Adams and his wife, Leizza, during which Adams repeated the disclosure. [1] [3]


When Robert “Kim” Mauzy replaced Herrod as bishop in 2012, Herrod told him about the abuse. Mauzy convened a formal Church disciplinary council. Adams again admitted his actions, this time before several council members. He was later excommunicated. [1] [3]


None of those disclosures resulted in a report to police or child-welfare authorities. [1] [3]


The abuse was uncovered in 2017 after the Department of Homeland Security found a video online. Paul and Leizza Adams were indicted. Leizza was sentenced to two and a half years in prison. Paul admitted the abuse to law enforcement but died by suicide in jail before trial. [1] [3]


Three of their children later sued the Church, the two bishops, and others. Their claims included negligence, breach of fiduciary duty, civil conspiracy, and failure to comply with Arizona’s reporting law. [1]


What Arizona Law Requires


Arizona law begins with a broad command. Any person who reasonably believes that a minor has been abused must immediately report it or cause a report to be made. [2]


The same statute contains an exemption for clergy. A clergy member who receives a confession or confidential communication may withhold it when that clergy member decides that silence is “reasonable and necessary within the concepts of the religion.” [2] [1]


That wording gives the clergy member the initial decision. The new ruling goes much further by sharply limiting who may review that decision afterward. [1]


An Arizona appellate court had previously ruled that a jury should be allowed to examine several unresolved questions. Was Adams’s admission still confidential when he repeated it in front of his wife? Was it confidential when he spoke before a disciplinary council? Did the bishops actually follow Church teachings when they chose not to report continuing abuse? [1]


The Court Deferred to the Church


The Supreme Court held that the First Amendment generally prevents courts and juries from deciding whether clergy correctly interpreted or followed their religion. [1]


It also said courts must give “substantial deference” to a religious institution’s understanding of what counts as a confession or confidential communication. Religious institutions are likewise allowed to determine who qualifies as clergy. [1]


The Church maintained that Adams’s admissions were confidential and that withholding a report was reasonable and necessary under Church doctrine. The court concluded that it was required to credit that determination. [1]


There is a narrow exception for evidence obtained through fraud or collusion for a secular purpose, such as fabricating a religious justification merely to avoid legal liability. The court found no such evidence in this record. [1]


The Abuse Help Line


The legal opinion says little about the Church’s abuse help line, but the history of this case cannot be understood without it.


A 2022 Associated Press investigation reported that Bishop Herrod contacted the Church’s help line after learning about the abuse. According to Herrod’s recorded statement to investigators, Church lawyers told him, “You absolutely can do nothing.” [3]


The AP investigation also found that the help line routed serious abuse reports to attorneys representing the Church. The Church has maintained that its system helps leaders comply with local laws and protect victims. Critics argue that the structure places legal risk management between a bishop and civil authorities at the moment a child may still be in danger. [3]


Lucifer’s Lantern previously addressed the danger of treating an ecclesiastical report as a substitute for contacting authorities in “It Takes a Village (Not a Church) to Protect a Child.” The Adams case is a grim example of that concern. Information moved from one bishop to another, into a disciplinary council, and through the Church’s internal system. It did not move to the people empowered to investigate the home and remove children from danger. [6] [1] [3]


Legal Protection Is Not Moral Vindication


The Church welcomed the ruling and said the abuse was reprehensible, that it condemns abuse, and that it devotes resources to prevention and victim support. [4]


But the decision does not establish that the Church’s response protected the children. It establishes that Arizona law, combined with the First Amendment analysis adopted by the court, shielded the bishops’ decision from civil review. [1]


The court stressed that religious institutions do not have general immunity from secular law. Still, the practical protection created here is broad. A church may define its clergy, characterize communications as religiously confidential, and explain that silence was required by doctrine. Unless plaintiffs can show fraud or secular collusion without first examining that doctrine, courts are expected to defer. [1]


For the children in this case, that distinction offers little comfort. Adults knew. An internal religious process took place. The abuser was removed from Church membership, but the children remained in the home. [1] [3]


Projects such as Floodlit, previously examined by Lucifer’s Lantern, preserve the records behind cases like this because legal outcomes can easily be mistaken for factual or moral exoneration. The Arizona Supreme Court did not find that the system worked. It found that the courts could not question the religious reasoning used to justify silence. [5] [7] [1]


A legal right to remain silent does not make silence the correct choice.


Sources


[1] Arizona Supreme Court, Doe et al. v. The Corporation of the President of The Church of Jesus Christ of Latter-day Saints, Opinion, July 30, 2026.


[2] Arizona Revised Statutes § 13-3620.


[3] Associated Press, “Seven Years of Sex Abuse: How Mormon Officials Let It Happen,” August 4, 2022.


[4] The Guardian, “Arizona Clergy Who Learn of Child Abuse in Confessions Aren’t Required to Report It, Court Rules,” August 3, 2026.


[5] FLOODLIT, “Paul Douglas Adams Mormon Sex Abuse Case.”


[6] Lucifer’s Lantern, “It Takes a Village (Not a Church) to Protect a Child.”


[7] Lucifer’s Lantern, “Floodlit: Shedding Light on Sexual Abuse.”


Comments

Popular posts from this blog

Mormon Blood and the Esther Cohen-Tizer-Epstein Letter

With the recent release of nearly 3.5 million pages of the Epstein files, there have been several connections made regarding Jeffery Epstein paying tuition for several students at BYU. The most notable of which is presented in what is known as the Esther Cohen-Tizer-Epstien Letter.    Some are questioning the authenticity of the letter, but some clues seem to point us to a woman named   Esther Cohen .  Lets look at a few connections. Note that these connections are not an attempt at making any accusations and are simply connections made through publicly available information. I will be updating this page as I find more information. EFTA00129111  Reference to the Seven Bowls School of Nutrition From Esther's website: alchemyofnourishment.com (Update March 04, 2026: The site seems to have been taken down) She began studying nutrition as a teenager: Which also seems to align with her site. Alchemy of Nourishment Along with the claim of residing in Colorado Alc...

How the Book of Mormon Has Changed Since 1830

     Discussion of changes to the Book of Mormon often settles into two opposing claims: either the book has remained essentially unchanged since 1830, or later editors rewrote it beyond recognition. The reality is that both positions carry a bit of truth. Although the main narrative remains recognizable, the book has changed in several distinct ways. Its wording and grammar were revised in the early editions.⁶ , ⁷ The chapter and verse system was reorganized in 1879, while chapter summaries were added in 1920.¹⁹ Those summaries and other study aids were revised again in 2013 and 2025.²⁰ , ²¹ Following these changes in chronological order makes their differences easier to see. The history begins with dictation in 1829 and continues through the original and printer’s manuscripts, the 1830 printing, Joseph Smith’s revisions, and the later editorial committees that produced the modern edition. Tracing that sequence also makes it possible to distinguish changes to the script...

The "Mormon" Trademark is About to Expire

 The request for Mormon Stories to rebrand has spread quickly through Mormon spaces. Followers learned that om November 14th 2025, the LDS Church had reached out with claims that the podcast was infringing on the “Mormon” trademark. The demand leaned on the legal idea that the Church owns the word.  The request was shared on social media by @mormstories, but those posts seem to have been removed. Fortunately, copies of the email were  shared on reddit. But there is a significant detail sitting behind this entire dispute. The Church will have to renew the "Mormon" trademark in the 2026 to 2027 window.  Source: USPTO database When that time comes, they must prove that they still use the word “Mormon” in active commerce. USPTO rules are clear on this point. A trademark only survives if the owner can show that it is still printed on actual goods or services that are still being sold or distributed. The official guidelines spell it out at uspto.gov under “ Keeping your r...

Everything You Need to Know About the Salt Lake Temple

  The Salt Lake Temple will open to the public from April 5 through October 1, 2027, before it is rededicated and again restricted to Latter-day Saints with temple recommends. [2] Reservations opened on September 1, 2026, and one million tour spaces were claimed in less than 24 hours. [1] The Church describes the event as only the second public open house in the temple’s 134-year history. [2] The building visitors will enter is both old and substantially new. [12] [13] Construction began in 1853 and ended with the temple’s dedication in April 1893, but the interior has been altered repeatedly since then. [3] [20] The current renovation adds about 100,000 square feet of underground space, two baptistries instead of one, five instruction rooms, and 22 sealing rooms instead of 13. [12] The temple now rests on 98 base isolators about 20 feet below the structure, part of a seismic system designed to allow substantial horizontal movement during a major earthquake. [14] [24] The chan...

Candon Dahle to Marry After Child Abuse Conviction

Former BYU baseball player Candon Dahle is expected to marry this week, less than a year after receiving a plea deal that allowed him to avoid sex offender registration despite admitting guilt to two felony counts involving the abuse of a child. News of the wedding has reignited criticism online, where many argue Dahle's return to ordinary life has come far too quickly in light of the allegations against him.  The topic was recently discussed on Instagram by  @justinthenickofcrime View this post on Instagram A post shared by Justin (@justinthenickofcrime) Dahle first made headlines in February 2025 when he was charged in Fremont County, Idaho, with felony lewd conduct with a child under the age of 16. According to the probable cause affidavit summarized by East Idaho News , prosecutors alleged Dahle sexually abused an 11-year-old girl and covered her mouth during one of the assaults. Authorities also filed a separate juvenile case in neighboring Bing...

Mormon Stories Fires Back: The Core Defenses Against the LDS Lawsuit

In April 2026, The Church of Jesus Christ of Latter-day Saints and its intellectual property arm, Intellectual Reserve, filed a federal lawsuit against the Open Stories Foundation and John Dehlin. The complaint alleges trademark infringement, copyright infringement, and consumer confusion arising from the use of the name Mormon Stories, its branding, and its use of Church-related images.      The Church portrays the case as a straightforward effort to protect its trademarks and prevent confusion among people seeking information about the faith. Mormon Stories sees the case very differently. In its response and counterclaim , the organization argues that the Church is attempting to claim ownership over a word that belongs to an entire religious movement while using intellectual property law against one of its most visible critics. Here are the major arguments at the center of the dispute.

Mormonism's Complicated History With Caffeine

Ask whether Latter-day Saints can drink caffeine and the current answer is yes. The Church’s own historical summary says caffeine has been “left to the judgment of individual Saints” and is not prohibited as a condition for receiving a temple recommend. [3] That answer is clearer today than it was for much of the twentieth century. Church leaders and publications repeatedly discussed caffeine as a drug, a poison, a potentially habit-forming substance, and at times as the apparent reason coffee and tea were objectionable. Some leaders extended that reasoning directly to cola drinks. In 1965, the First Presidency even told a bishop that decaffeinated coffee did not violate the Word of Wisdom and should not disqualify an otherwise worthy member from a temple recommend.[5] The result was a long period in which formal policy, medical explanation, and everyday Mormon culture did not always point in exactly the same direction. That history helps explain why older and younger Latter-day Saints...

No. The Mormon Church is Not Suddenly Opposed to Gambling

Almost immediately after President D. Todd Christofferson said, “Gambling is morally wrong,” during the October 2026 General Conference, the LDS apologetic account @allthoseinfavor reacted as though the Church had just drawn a new moral line on gambling. Which personally is a bit concerning, seeing as the account runs a podcast discussing all aspects of Mormonism, including the history of the church. So I find it hard to believe that they haven't ever encountered the anti-gambling position of the church in their studies. Christofferson’s talk was certainly timely. He described a world in which smartphones have made sports betting, casino-style games, and prediction markets available almost anywhere, and he warned against treating an occasional wager as harmless entertainment.[1] But the moral judgment itself was not new. In fact, the Church had used almost the same words more than a century earlier. In August 1908, Church President Joseph F. Smith addressed speculation and gambling...

John Corrill followed Joseph Smith for six years. This was his conclusion.

  John Corrill’s 1839 history is easy to quote as an anti-Mormon source. That misses what makes it useful. Corrill did not spend the early years of Joseph Smith’s movement standing outside it. He joined after trying to disprove it, defended the Saints against accusations he thought were false, served in church leadership, and eventually decided that the movement was a false religion. [1] [2] What changed his mind was a pattern which he had watched develop from the inside: failed plans, financial collapse, pressure against dissenters, escalating militancy, and promises of divine protection that always ended in disaster. [1] That makes Corrill’s story more useful than a simple hostile exposé. It records both why an intelligent early convert believed and why he later stopped believing. The complete 1839 text is available in the Lucifer’s Lantern Full Text Library, including Corrill’s own account of his conversion, church service, the Missouri conflict, and his final remarks to the S...

Mormonism and the Satanic Ritual Abuse Scare of the 1980s

       All right. So, for this post today, I’m going to be talking about a pretty sensitive subject. And that’s going to be satanic ritual abuse and potential ties to leadership of the Mormon church.      It should go without saying that this is going to be a little bit more of a sensitive subject. I’ll say up front that I have no intention of diving into specific examples—detailed descriptions of what satanic ritual abuse looks like—outside of broad definitions. My goal is just to give an idea of what makes ritual abuse a little bit different than regular abuse (for lack of a better word). Consider this your heads up that this is going to be a sensitive subject.      I typically wouldn’t really give this type of subject very much attention. I certainly never planned on making a post about it. But I did have an interesting conversation the other day with an LDS content creator that I message with sometimes. I was a little surprised whe...