Arizona Supreme Court

Doe v. the Corporation

July 30, 2026

Summary

The Arizona Supreme Court affirmed the trial court’s summary‑judgment granting the Church defendants’ motion, holding that the First Amendment bars a factfinder from probing a clergy member’s doctrinal determination of whether to withhold reporting child abuse. The Court defined “confession” and “confidential communication” for the reporting statute, found the clergy‑exemption elements satisfied, and held the clergy‑penitent privilege irrelevant to the reporting duty.