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.
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?
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.”
At this year’s State Bar of Arizona Convention, Secular AZ and the Religious Liberty Law Section co-sponsored the panel From Pulpit to Precedent: The Johnson Amendment on Trial.
For seventy years, the Johnson Amendment has prohibited churches and nonprofits from endorsing candidates. Rarely enforced but often debated, the Amendment continues to raise questions about free speech, free exercise, church autonomy, campaign finance, dark money, tax privileges, and the boundaries of church-state separation. Today, courts, the IRS, and litigants on all sides are still testing its limits, creating ongoing uncertainty about how the rule will be interpreted and applied.
Dianne Post, Secular AZ Legal Director, summarizes the experience.
Arizona’s HB2312, signed by the Governor on 3/12/2026, is built on a federal law framework called Title 36 of the United States Code. This law lists certain “patriotic and national organizations” that Congress has officially recognized for their civic and educational role. These include groups like the Boy Scouts of America, Girl Scouts of the USA, Boys & Girls Clubs of America, Big Brothers Big Sisters of America, National FFA Organization, National 4-H Council, YMCA, American Legion, Veterans of Foreign Wars, Disabled American Veterans, and the American Red Cross.
Focusing on the provision of gender-affirming care, Health Care Civil Rights analyzes the difficulties and potential of discrimination law in healthcare settings. The application of civil rights law could be a powerful response to health inequalities in the US, but conservative challenges and the complex and fragmented nature of our health care system have limited the real-world success of this strategy. Revealing deep divides and competing interests that reverberate through patient experiences, insurance claims, and courtroom arguments, Anna Kirkland explains what health care civil rights are, how they work in theory and practice, and how to strengthen them.
Anna Kirkland is the Kim Lane Scheppele Collegiate Professor of Women’s and Gender Studies at the University of Michigan. She is author of Vaccine Court: The Law and Politics of Injury and Fat Rights: Dilemmas of Difference and Personhood.
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.
On March 31, 2026, two federal judges issued very different rulings in two major church-state cases. Even though the cases involved different issues and were decided in different ways, both outcomes favored keeping important boundaries and church and state separation in place.
What does it mean for public schools, and public institutions generally, to remain “neutral” on religion? That question is at the heart of two important legal battles currently shaping the boundaries of secular law. Stinson v. Fayetteville School District (2025)and St. Isidore of Seville Catholic Virtual School v. Drummond (2025), while arising in different states and contexts, both explore a core tension testing how far the government can go in engaging with religion before it crosses the line.
The guidance explains how federal law and Supreme Court precedent apply to prayer and religious activity in public schools, and it carries significant consequences because federal education funding depends on compliance. At the same time, Arizona lawmakers are considering multiple bills involving school board prayer, released-time religious instruction, and other religion-related policies that raise constitutional questions.
Join us on April 10 at noon for special guest Amelia Craig Cramer for a discussion of the state of the rule of law and criminal prosecutions in Arizona.
Amelia Craig Cramer is past President of the State Bar of Arizona and retired Chief Deputy Pima County Attorney. Following her retirement, Ms. Cramer served on the Arizona Supreme Court’s Task Force on Ethics for Government Lawyers and on the APAAC Public Law Practice Work Group.
Before joining the Pima County Attorney’s Office, during the first half of her legal career, Ms. Cramer was a civil litigator at large, private law firms: Baker & Hostetler in Washington D.C.; Heller, Ehrman in San Francisco, and Brown & Bain in Tucson. Additionally, she was a leader of two nonprofit legal organizations dedicated to LGBT civil rights: managing attorney of the western regional office of Lambda Legal Defense and Education Fund in Los Angeles; and executive director of GLBT Advocates and Defenders in Boston.
Also, Ms. Cramer taught law briefly as an adjunct professor at U.C. Berkeley’s School of Law and as a guest lecturer at other law schools. Following her retirement, Ms. Cramer volunteered for four years with the NAACP, serving as its Arizona State lobbyist and vice president and criminal justice committee chair of its Tucson Branch. Ms. Cramer is a graduate of Dartmouth College and Stanford Law School.
Join us on February 27 at noon (MST) for special guest SOSAZ for a discussion of the Protect Education Accountability Now Act. Get involved and volunteer to help here.
This year Arizona’s ESA voucher program is on track to spend more than $1,000,000,000 in your taxpayer dollars — with no accountability or transparency.
We can protect students and stop fraud by passing the Protect Education, Accountability Now! Act.