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.

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Religion has long played a significant role in shaping societies, influencing culture, traditions, moral values, and community life. For many people, faith provides a sense of identity, purpose, and belonging, and religious institutions have made lasting contributions through education, healthcare, charitable work, and community service. At the same time, history demonstrates that religion has also been a source of conflict and division, particularly when religious beliefs become intertwined with political power. Throughout history, religious ideas and institutions have at times been used to justify wars, persecution, discrimination, and unequal treatment of minority communities. Women have often faced restrictions on their rights and opportunities based on religious or patriarchal interpretations, while LGBTQ+ individuals have frequently encountered exclusion, criminalization, or social stigma justified on religious grounds.

These experiences illustrate why democratic societies continue to grapple with a fundamental constitutional question: how can governments protect every person’s freedom of belief while ensuring that no belief system is given legal or political preference over others?

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The case of Landor v. La. Dep’t of Corr. & Pub. Safety, No. 23-1197, slip op. (U.S. June 23, 2026) sits at the intersection of federal funding law and religious liberty in prisons. At its core, the dispute concerns the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), a federal statute passed under Congress’s Spending Clause power. RLUIPA says that when states accept federal funds for prisons, they must not substantially burden an incarcerated person’s religious exercise unless the restriction is the least restrictive means of furthering a compelling governmental interest.

Damon Landor, a Rastafarian prisoner, alleges that prison officials violated his religious beliefs by forcibly shaving his head despite knowing that his faith required him to keep his hair uncut. According to Landor, when he was transferred to another prison near the end of his sentence, he provided the new officers with a copy of an order protecting his religious practice. He alleges that the officers disregarded the order, discarded it, and cut his hair anyway. For Landor, the violation was not simply a disagreement over prison policy; it involved the loss of a religious practice that he believed was central to his faith. He sued under RLUIPA, seeking relief against both the Louisiana Department of Corrections and the individual prison officers in their personal capacities.

The key legal question before the Supreme Court was whether RLUIPA’s Spending Clause framework allows prisoners to seek monetary damages from individual state officers who themselves were not parties to the federal funding “agreement.”

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In the wake of the September 2025 assassination of Turning Point USA founder and activist Charlie Kirk on a Utah university campus, a massive online backlash emerged. Right-wing influencers and accounts, such as “Libs of TikTok,” combed social media to identify and publicly expose individuals who made critical or lighthearted posts about Kirk’s death. However, recent legal developments have revealed that the government fallout from these events has carried a steep public price tag.

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