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
[2] Arizona Revised Statutes § 13-3620.
[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.”
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