Sexual abuse in churches and religious organizations: how claims work

Legal accuracy check

Chris Schroeder, Esq.

Florida Bar #520381 · D.C. Bar

First published October 5, 2026 · Last checked October 5, 2026

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How claims against churches and religious organizations work

This page covers Protestant churches, the Church of Jesus Christ of Latter-day Saints, Jehovah’s Witnesses congregations and other religious bodies. Catholic dioceses have their own page, Catholic diocese lawsuits, because so many of them are in bankruptcy, and the six California cases are tracked on our California diocese bankruptcies page. Every kind of institution we cover is listed on the institutions hub.

Negligence: hiring, supervision and retention

A religious organization is usually sued the same way as any other private organization, under state common law. Negligent hiring, supervision and retention are the core claims, and the details vary by state. Did the church check the background of the pastor, youth leader, teacher or volunteer? Had anyone complained, and what did leaders do with the complaint? Did the church keep the person in a role with access to children after it had reason to worry? Claims for breach of fiduciary duty and civil conspiracy are sometimes added, as in the Arizona case described below.

What a court can and cannot decide

The First Amendment limits what a civil court may examine. Courts may decide disputes that arise in religious settings “by applying neutral principles of law without inquiry into religious doctrine,” the Arizona Supreme Court said on July 30, 2026, quoting earlier precedent. A claim that a church ignored warnings about an employee can usually be decided that way. A claim that depends on what a faith requires cannot.

Title IX, the federal law used against schools, applies only to education programs or activities that receive federal financial assistance. A school a church runs may be covered if it takes federal funds, which our page on private and religious schools explains.

Mandated reporting and the clergy privilege

Every state requires some people to report suspected child abuse. Whether clergy are among them differs by state. According to the federal Children’s Bureau’s Child Welfare Information Gateway, in a survey current through May 2023, approximately 29 states and Guam name clergy as mandated reporters, and approximately 16 states, Puerto Rico and the Virgin Islands require “any person” who suspects abuse to report it, language that appears to include clergy. In Ohio and Wisconsin, a clergy member must report reasonable cause to suspect that another clergy member has abused a child.

Many of these laws also protect what a person tells clergy in confidence, often called the clergy-penitent privilege. The Gateway’s summary says the privilege “is not absolute” and is “typically interpreted narrowly” in child abuse cases, and that New Hampshire, West Virginia and Guam deny it in cases of child abuse or neglect. States amend these laws often, so the count is a starting point, not a rule for any one state.

Arizona shows how the two rules meet. Its reporting statute, A.R.S. 13-3620, lists members of the clergy among those who must “immediately report” reasonable belief that a minor has been abused. It then allows clergy who receive “a confidential communication or a confession” in that role to withhold reporting it if they determine that doing so “is reasonable and necessary within the concepts of the religion.” The exemption covers only the communication, “not ... personal observations” of the child.

On July 30, 2026, in Doe I v. Corporation of the President of the Church of Jesus Christ of Latter-day Saints (No. CV-25-0213-PR), all seven justices of the Arizona Supreme Court held that the First Amendment “generally prohibits factfinders from inquiring into a clergy member’s application of his particular religious doctrine,” absent fraud or collusion for secular purposes, when deciding whether withholding a report was reasonable and necessary. The court also held that courts must give “substantial deference” to a religious institution’s own understanding of what counts as a confession, and that the institution may define who is a member of its clergy. It affirmed summary judgment for the Church defendants. The Church defendants had argued that they owed the children no duty under the reporting statute, and the trial court found that the father’s disclosures were confessions or confidential communications. The ruling decided those legal questions. It did not find that the abuse did not happen: the opinion records that the children’s mother pleaded guilty and was sentenced to two and a half years in prison, and that the father confessed to police and died in jail before trial.

The decision binds Arizona courts only, and other states write their reporting laws and privileges differently.

Who can be held responsible

Religious bodies are organized in very different ways, and the structure decides who can be named. A claim may be brought against the local congregation, a regional body, the national corporation, or all of them, depending on who hired, trained and supervised the person and who knew what. In the federal cases against the Church of Jesus Christ of Latter-day Saints, the defendants included the Church “and more than thirty unincorporated and incorporated ecclesiastical subdivisions,” according to the Judicial Panel on Multidistrict Litigation’s April 3, 2025 order.

Reaching a national body can be its own fight. In Montana, survivors suing two Jehovah’s Witnesses corporations litigated whether the federal court there had jurisdiction over Watch Tower Bible and Tract Society of Pennsylvania. On July 7, 2025, the Ninth Circuit affirmed sanctions against that corporation’s general counsel for an affidavit on the jurisdiction question that showed “a reckless disregard for providing an accurate and truthful accounting of facts.”

The person who committed the abuse can be sued as well, and a criminal case can run at the same time; see civil and criminal cases. Our pages on child sexual abuse, grooming and adult sexual assault describe patterns that often appear in these records, including abuse of adults by pastors and counselors.

Deadline issues for churches and religious organizations

Revival windows and current limits. Many older church cases depend on a law that reopened expired claims. New York’s Child Victims Act window under CPLR 214-g ran from August 14, 2019 to August 14, 2021, and California’s AB 218 window closed on December 31, 2022. Both have closed. New Jersey now lets survivors of childhood sexual abuse sue “any time before reaching the age of fifty-five.” California has no time limit for childhood sexual assault that occurred on or after January 1, 2024 (Code Civ. Proc. 340.1). Maryland removed its time limit for childhood sexual abuse claims on October 1, 2023, and its Supreme Court upheld that change, 4 to 3, on February 3, 2025.

Charitable immunity. A few states have shielded nonprofits, churches included, from negligence suits. New Jersey has cut that shield back for abuse: P.L.2005, c.264 removed it for negligent hiring, supervision or retention that resulted in a sexual offense against a minor, and P.L.2019, c.120, effective December 1, 2019, removed it for willful, wanton or grossly negligent acts including sexual abuse.

Bankruptcy. When a religious organization files for Chapter 11, the court sets a claims deadline, called a bar date, that can control even where state law has no limit. That has happened mainly with Catholic dioceses so far, and the diocese page explains how it works. The state-by-state rules are in our statute of limitations reference.

Active matters involving churches and religious organizations

Each line is an allegation unless it says a court has ruled. Status is as of the date given.

Church of Jesus Christ of Latter-day Saints

On April 3, 2025, the Judicial Panel on Multidistrict Litigation refused to combine 41 federal actions pending in nine districts. The plaintiffs allege they were abused by people associated with the Church and attribute the abuse to an alleged nationwide policy of concealment. The Church opposed combining the cases. The Panel found the cases too varied, with alleged abuse “from 1968 to 2023” by clergy, missionaries, teachers, church members and family members, and said discovery would focus on “whether and to whom each plaintiff reported the alleged abuse and how those individuals responded.” In California, 91 suits were filed beginning August 26, 2024, and a settlement in principle was reached at mediation on April 10, 2025 with confidential terms, according to news reports collected by BishopAccountability.org. In a statement quoted by azfamily on September 30, 2026, the Church said that “the abuse of a child or any person is a tragic betrayal of trust” and that it devotes significant resources to preventing abuse and encouraging reporting.

Southern Baptist Convention

Most court activity involving the Southern Baptist Convention in 2026 has been defamation suits by men named in its 2022 Guidepost report, not survivor claims; a federal judge in Tennessee ruled on one of them on September 29, 2026. On the survivor side, a proposed class action filed August 5, 2026 in federal court in South Carolina over Pawleys Island Community Church and Christian Academy names the SBC and its Executive Committee among other defendants, according to the Roys Report. The SBC told that outlet it “does not comment on ongoing litigation.”

Jehovah’s Witnesses

Pennsylvania’s Attorney General announced on July 9, 2025 that a statewide grand jury hearing testimony about alleged abuse by members of Jehovah’s Witnesses congregations had led to charges against a 17th member since 2022. Those are criminal charges, and each person charged is presumed innocent unless convicted. We have not confirmed the current status of the Montana civil cases described above. The organization’s position on the underlying allegations is not in the records we reviewed.

Where to go next

Abuse at a church school is covered on our page about private and religious schools, and abuse at a church camp or youth group under camps and youth programs. Reporting abuse explains how to report to police or child protective services directly, without going through church leaders. Many survivors sue under initials; our guide to filing anonymously explains how, and how to file a claim walks through the process. If you want a lawyer to look at your own dates, a free, confidential case review costs nothing and commits you to nothing.

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