What the Arizona Supreme Court’s Decision in Doe v. Church of Jesus Christ of Latter-day Saints Means
What happens when a law designed to protect children intersects with constitutional protections for religious autonomy? The Arizona Supreme Court’s decision in Doe v. The Corporation of the President of The Church of Jesus Christ of Latter-day Saints addresses this question: whether statements made by Paul Adams to LDS bishops regarding the abuse of his children were protected under Arizona’s clergy exemption to mandatory child abuse reporting laws, or whether the bishops had a legal obligation to report the information to authorities. The case was not simply about religious confidentiality; rather, it required the Court to examine whether the communications satisfied the requirements of Arizona’s clergy exemption and whether applying the reporting law would improperly interfere with religious autonomy. The decision reflects the broader challenge of balancing the state’s interest in protecting children from harm with constitutional protections that limit government involvement in religious practices and internal religious decisions.
When Religious Confidentiality Meets Child Abuse Reporting




