Arizona clergy who learn of child abuse in confessions aren’t required to report it, court rules
State supreme court rules in case of two bishops who were silent about three children abused by Mormon parents
Clergy members in Arizona who learn of child abuse in the context of religious confession are not required to report it, the state’s supreme court has said in a ruling that protects what church leaders call the “seal of the confessional”.
The panel’s ruling ends a long-running case in which three children who were sexually abused by their parents sued the Church of Jesus Christ of Latter-day Saints (LDS), also known as the Mormon church, and two bishops who became aware of the crimes but remained silent.
The case has parallels in a short-lived 2025 law in Washington state that would have compelled clergy members there to report sexual abuse. That proposal was permanently withdrawn in October after legal action by the Catholic church.
In a statement, the LDS welcomed the unanimous ruling by the state supreme court on Thursday that exempts clergy members as “mandated reporters” if they learned of the abuse of minors in the confession booth or through other “confidential” methods.
“The abuse of a child or any person is a tragic betrayal of trust,” it said. “The abuse at the center of this case was reprehensible, and the church has always condemned it. The church is deeply concerned for these children and for all who have suffered abuse.
“The church devotes significant resources to preventing abuse, helping victims, and encouraging reporting through safeguarding efforts around the world. The church has always been willing to help the victims in this case and that continues to be true.
“Arizona law also recognizes the confidential nature of religious confession. [The] decision affirms that these religious protections are to be respected alongside society’s shared commitment to protect the vulnerable.”
The case centered on a 2020 lawsuit filed by the children of Paul and Leizza Adams, who reported being abused by the Cochise county couple over a number of years.
Court filings said Paul Adams, who took his own life in jail while awaiting trial, admitted his crimes to a bishop while in confession in 2011. And, court filings said, they were discussed at a formal disciplinary hearing led by a separate bishop the following year.
A 2022 investigation by the Associated Press, however, recounted how the church followed its own policy of keeping the information to itself. The second bishop called an internal church helpline for advice, the AP reported, but was advised not to call police or child welfare officials.
The abuse continued, and it was not until 2017 that Adams and his wife were arrested after a video they made of some of the abuse turned up in New Zealand. Adams died awaiting trial, and Leizza Adams received a 30-month sentence in 2018 after pleading no contest to two felony charges of child abuse.
The Arizona supreme court’s ruling overturned a state appeals court ruling for the children on the grounds that the confession and disciplinary hearing discussions might not have been truly confidential.
In the 23-page ruling, John Lopez, the supreme court vice-chief justice, said the US constitution’s first amendment – which addresses religious freedom – prevented courts and juries from assessing religious doctrine when considering a clergy member’s reasons for choosing not to report abuse.
“Our decision ‘does not mean that religious institutions enjoy a general immunity from secular laws’,” he wrote, citing a 2020 US supreme court ruling about the church’s right to determine matters of government, faith and doctrine “free of government interference”.
“If a court finds a religious institution submitted evidence procured through ‘fraud’ or ‘collusion’ for secular purposes, it will lose the religion clauses’ protection” in the constitution.
There was no evidence the LDS church had done so, Lopez wrote.
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HIV-positive pastor shocks community, charged with abuse of 14-year-old boy: 'Jesus don't like that'
An HIV-positive Florida pastor is accused of sexually abusing a 14-year-old boy he met on a dating app, after allegedly going online to target children. The case has left residents shocked and horrified.
Timothy Chaneyfield, 42, the pastor at St. James United American Free Will Baptist Church in Winter Haven, is facing several charges and was transferred to the Polk County Jail, Polk County Sheriff Grady Judd said during a press conference Tuesday. He is being held on a bond of over $350,000.
Chaneyfield faces the following charges: three counts of lewd battery of a minor, three counts of interfering with custody of a minor, one count of unlawful use of a two-way communication device, three counts of traveling to meet a minor, four counts of an HIV-infected person having sex without informing a partner, one count of possession of cannabis, and five counts of possession of drug paraphernalia.
Judd said investigators spoke with members of the St. James church, who were “shocked” and said, “they had absolutely no idea their pastor was like that.” The investigation revealed that Chaneyfield had gone online searching for children and met the 14-year-old boy through a dating app.
According to the Polk County Sheriff's Office (PCSO), the investigation began on July 28 after a cyber tip from the National Center for Missing and Exploited Children. The tip came from Instagram, where Chaneyfield and the victim continued chatting after meeting on the dating app.
“And then Timothy Chaneyfield picked him up in front of his neighborhood on three different occasions,” Judd said. “And on those three different occasions, he wasn't preaching, but he was messing around.”
Investigators said Chaneyfield picked up the victim on three consecutive days at the entrance to his subdivision, drove him to his house in Winter Haven and sexually abused him.
The pastor allegedly told the victim during a phone call that he wanted to continue having sex with him. He also told the boy he had to travel to Baltimore; investigators later learned he was presiding over a funeral there.
Authorities also learned that Chaneyfield was a chaplain for Compassionate Care Hospice of Lakeland. A spokesperson for Amedisys Home Health Care, the hospice's parent company, told The Christian Post that the company is aware of the allegations and confirmed that Chaneyfield is no longer employed there.
“We will cooperate fully with law enforcement authorities and their investigation,” the Compassionate Care Hospice spokesperson said. “Our priority remains delivering compassionate, high-quality care and support to the patients and families we serve.”
CP attempted to contact St. James United American Free Will Baptist Church for comment, but the phone number was disconnected.
“I hope that all of [the victims] come forward because this is wrong,” Teresa Story, a Winter Haven resident, said in a statement to Nexstar’s WFLA. “The Lord is going to judge him at the end of the day, but the law’s got to judge him too.”
A detective obtained a warrant for Chaneyfield’s arrest, and with help from the Orlando Police Department, authorities took him into custody when he returned to the Orlando airport on July 29.
“But that wasn't it. That wasn't all. Timothy is HIV-positive,” Judd said.
Judd said Chaneyfield did not disclose his HIV-positive status to the 14-year-old victim, nor to another man he had sex with who is now HIV positive, according to Judd.
Judd said authorities gave the 14-year-old victim preventive HIV medication and hope it was administered in time to prevent infection.
“[Chaneyfield] groomed a child online, drove to the child's neighborhood, picked him up, took him to his home, had sex with him, and if that's not bad enough, never disclosed to the child that he's HIV-positive,” the sheriff said. “So, ‘I'm going to have unprotected sex with this child and infect him as well.’”
“Jesus don't like that. And he'll have to answer for that one day to a court much higher than ours,” he added.
The sheriff is concerned Chaneyfield may have abused other children, noting the pastor had worked with children at Crystal Lake Middle School in Lakeland.
Polk County Public Schools, where Chaneyfield worked from 2012 until 2024, did not immediately respond to CP’s request for comment. This article will be updated if a response is received.
In a statement to WTSP, a spokesperson for Polk County Public Schools said Chaneyfield started as a substitute teacher in 2012, then worked as a paraeducator from 2014 to 2016 and as a network manager from 2016 to 2024, before leaving the district.
"We are thankful that the Polk County Sheriff's Office arrested this individual to protect the community from any further harm," the school district said. "As always, we cooperate fully with law enforcement to protect students and staff."
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