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.
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.
Public schools are supposed to belong to everyone. But in Arizona, a growing push from LifeWise Academy and a bill moving through the legislature threatens to blur the line between private faith and public education in ways that should concern everyone, no matter what they believe.
Last night, I put a reminder on my phone, telling me to watch the entire video of President Obama and NYC Mayor, Zohran Mamdani reading and singing to a preschool class somewhere in New York. I had seen a few clips of it, and even sent some to my daughter to show to my grandson since they sang one of his favorite, absolute BANGERS, “The Wheels on the Bus.”
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.
Hey Secular FAM! The world is moving at lightning speed, so today I’m leaning into that vibe.
I celebrated my fourth anniversary with Secular AZ at the end of last year, and I swear, this spring has been the busiest on record. This year, Secular AZ has been at dozens of in-person street fairs, festivals, and home tours, tracked hundreds of bills, spoken at countless events, and collaborated with stakeholder groups in Arizona and nationally. We also do our best to track the most problematic governing bodies in the state, like the PUSD governing board and the Mohave County Board of Supervisors.
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.