The Help Line: Theology, Statute, and Duty
In 1974, the federal Child Abuse Prevention and Treatment Act pushed states toward mandatory reporting laws for teachers, doctors, and other adults with regular access to children. In 1992, an LDS apostle delivered a general conference address instructing members who experience abuse to bring it to their bishop. In 1995, the LDS Church established a national help line instructing bishops, in turn, to call a law firm before deciding whether to report abuse to police.
This entry traces that sequence, doctrine, statute, and institutional mechanism, through four documented cases spanning four states and four decades, and ends with the Arizona Supreme Court's second and final ruling in the Adams case, decided July 30, 2026, closing the question of what duty this institution owes a child once abuse is disclosed to a bishop.
A help line, by its name, promises assistance to the person who calls it. Court records describe a different function: routing the call away from the people who could stop the harm, and toward the people paid to limit what the institution owes for it.
The mechanism, as described in court filings
The doctrine, 1992
Richard G. Scott, then a member of the Quorum of the Twelve Apostles, delivered "Healing the Tragic Scars of Abuse" at the April 1992 general conference, a talk still cited by the church's own study materials today. Alongside counsel on recovery, the address directed victims toward their priesthood leader as the primary channel for disclosure, and placed a share of responsibility on the victim's own conduct:
"The victim must do all in his or her power to stop the abuse. Most often, the victim is innocent because of being disabled by fear or the power or authority of the offender. At some point in time, however, the Lord may prompt a victim to recognize a degree of responsibility for abuse. Your priesthood leader will help assess your responsibility so that, if needed, it can be addressed."
The talk directs victims to "leave the handling of aggressors to others," church and civil authorities acting together, with the bishop as the point of first contact. Sixteen years later, Scott delivered a revised version of the same counsel, "To Heal the Shattering Consequences of Abuse," at the April 2008 general conference, addressed to both victims and, explicitly, to those who cause abuse.
The mechanism, 1995
The LDS Church established its national abuse help line in 1995, operating not within its Family Services counseling arm but inside its Office of Risk Management, a department whose stated purpose is limiting the church's financial and legal exposure, and which reports to the First Presidency. According to sworn statements and sealed depositions later obtained by the Associated Press, calls are answered by social workers who ask a scripted set of questions. When the abuse is judged serious enough to expose the church to liability, the call is transferred to attorneys at Kirton McConkie, the church's outside law firm.
Those attorneys, not the social workers, then determine what happens next. The church has maintained that everything discussed with those attorneys is protected by attorney-client privilege, unreachable by subpoena in later litigation. Notes taken during the initial call are destroyed at the close of each business day.
Officials describe the help line as a resource to guide local leaders through their reporting obligations, staffed by trained counselors, and say confidentiality protections exist to preserve the sanctity of religious confession, not to shield wrongdoing.
Four cases
What follows are four separate, independently documented instances of this mechanism in operation, in four different states, spanning more than a decade.
Michael Jensen, from a prominent Mormon family in Utah and later West Virginia, was charged in Provo in 2004 with felony sexual abuse of two girls, pleading guilty to reduced misdemeanor counts in the presence of a bishop and his own parents, who later became local church leaders themselves. The family relocated to Martinsburg, West Virginia the following year. There, according to plaintiffs, church leaders continued to recommend Jensen as a trusted babysitter to families in the congregation, even as reports of continued abuse allegedly reached church volunteers, until his 2013 arrest and eventual conviction for the sexual abuse of children as young as two and three, resulting in a 35-to-75-year prison sentence.
Nine children and their families sued the church for negligence and civil conspiracy. The West Virginia Supreme Court reversed a lower court's summary judgment in the church's favor in 2017, allowing the case to proceed toward trial. The case settled mid-trial in 2018 on undisclosed terms, the church calling it, at the time, the largest sexual-abuse settlement it had ever paid. The actual figures remained sealed for seven years. In March 2025, the independent newsroom FLOODLIT.org revealed the church paid a $32 million settlement and spent over $27 million in legal defense, nearly $60 million in total.
Susan Brock, an LDS church member in Chandler and the wife of Maricopa County Supervisor Fulton Brock, began a sexual relationship with a teenage boy from her ward when he was fourteen. In October 2009, the boy's father raised suspicions of abuse directly to Brock in a meeting with the family's LDS stake president; Brock denied it, and no one at the meeting called police. The relationship continued for another year, disclosed by accident in October 2010 when the boy's girlfriend found sexually explicit text messages on his phone. Brock confessed the relationship to her bishop, Matthew Meyers, who called the boy's bishop, Troy Hansen, and separately called Kirton McConkie, the church's law firm. Neither bishop reported the relationship to police or to the boy's parents. The abuse involved religious symbology Brock deployed during the encounters themselves, a detail that later became part of how the case was used in law enforcement training on institutional and familial patterns of abuse in insular religious communities.
The boy's parents learned what had happened independently and went to Chandler police on October 22, 2010, ten days after Meyers first learned of it. Brock was arrested and pleaded guilty in April 2011 to three counts of attempted sexual conduct with a minor, receiving a thirteen-year prison sentence; she was released in December 2021. Chandler Police Department lead detective Christopher Perez recommended in his report that Meyers and Hansen be charged under Arizona's mandatory-reporting statute, A.R.S. § 13-3620, for failing to report the abuse once they knew of it. The Pinal County Attorney's Office declined to prosecute either bishop. The church stated the bishops had acted properly under Arizona's clergy-confession exemption and said they had been "instrumental in getting the matter reported to law enforcement authorities," a characterization Chandler police's own report contradicts: it was the victim's family, not the church, that went to police.
Paul Adams, a U.S. Border Patrol agent stationed in Bisbee, confessed to his bishop, John Herrod, that he had sexually abused his older daughter. The sworn record disagrees on when: Herrod's own declaration places it in late 2011, while Leizza Adams's contemporaneous journal entry, corroborated by a friend's testimony and an FBI agent's report of Leizza's own account, places it in 2010. Herrod was, separately from his religious office, a mandated reporter under Arizona law by virtue of his profession as a family physician. Rather than report to police, Herrod called the church's help line and was directed to Kirton McConkie, where attorney Merrill Nelson, also a sitting Utah state legislator, advised on the matter; call logs filed in the case show contact between Nelson and Herrod, and later Herrod's successor, Bishop Robert "Kim" Mauzy, running from November 2011 to February 2014. Adams's abuse of his daughters continued for years and was documented on video and shared online. Associated Press reporting found that footage from the case was referred to the National Center for Missing and Exploited Children 1,850 times and contributed to nearly 800 federal child pornography arrests in a single year; Cadigan, representing the children, has separately put the number of people charged in connection with the video at more than 300. Federal investigators, acting with no assistance from the church, identified and arrested Adams in 2017. He confessed to law enforcement but died by suicide in jail before trial. His wife, Leizza, who was present when Adams later repeated his confession, pleaded guilty to failing to report the abuse and was sentenced to two and a half years in prison, and was released in 2020.
Adams's three children sued the church, two bishops, and other church members in 2021, alleging negligence and conspiracy. On August 8, 2022, Cochise County Superior Court Judge Laura Cardinal ruled that Adams's own subsequent conduct, posting the videos, boasting about the abuse on social media, confessing to federal agents, amounted to a waiver of his own clergy-penitent privilege: "his acts can only be characterized as a waiver of the clergy-penitent privilege." The church sought special action review, and on December 15, 2022, a three-judge Arizona Court of Appeals panel vacated Cardinal's order, holding that Adams had publicly disclosed only the underlying conduct, not the content of his confession itself, and that disclosing the same facts a confession concerns does not waive privilege over the confession. On April 7, 2023 (made public April 11), the Arizona Supreme Court declined further review, letting the Court of Appeals ruling stand and confirming the church could refuse to produce Adams's 2013 excommunication and disciplinary records under the state's clergy-penitent privilege statute. "The Church of Jesus Christ of Latter-day Saints agrees with the Arizona Supreme Court's decision," the church said at the time. "We are deeply saddened by the abuse these children suffered." Cadigan called the ruling an expansion of the privilege beyond what the legislature intended, warning it lets churches conceal crimes against children.
On remand, Cochise County Superior Court Judge Timothy Dickerson dismissed the suit outright on November 3, 2023, finding the church's knowledge of the abuse came entirely from communications protected by clergy-penitent privilege. Cadigan said she would appeal, asking how the courts explain to young victims that a rapist's religious beliefs are more important than their right to be free from rape. On July 30, 2025, a three-judge Arizona Court of Appeals panel unanimously reversed that dismissal. Writing for the panel, Judge Christopher P. Staring held a jury could reasonably find Adams had waived his privilege a second time by repeating his confession in front of his wife and again before the full church disciplinary council that upheld his excommunication: "A jury could reasonably infer that Paul's actions in the later proceeding voluntarily waived the clergy-penitent privilege for the purpose of disclosing his abuse of Doe to all members in attendance, clergy and non-clergy alike." Attorney John Trebon, who argued alongside Cadigan for the children, said the ruling mattered because it prevents clergy from hiding abuse the law requires them to report.
The church appealed again, joined this time by amicus filings from the Roman Catholic Dioceses of Phoenix, Tucson, and Gallup, all three of which have separately faced their own allegations of covering up clergy sexual abuse, with the Tucson diocese having filed for bankruptcy in the early 2000s over related litigation, arguing that a ruling for the Adams children would itself violate the First Amendment. On July 30, 2026, the Arizona Supreme Court, in a unanimous opinion by Vice Chief Justice John Lopez, reversed the Court of Appeals and reinstated summary judgment for the church, this time on a broader ground than the 2023 ruling had used. The court held that Arizona's clergy-penitent privilege is a testimonial privilege only, governing whether a clergy member can be compelled to testify, and is therefore irrelevant to whether a duty to report existed in the first place. The dispositive holding rested instead on the First Amendment: courts and juries may not examine how a church interprets its own religious doctrine, including which disclosures, to a spouse, to a disciplinary council of clergy and lay members alike, count as confidential religious communication under that church's own teaching. The court allowed a narrow exception for fraud or collusion to evade legal responsibility, and found no such evidence here.
Cadigan argued the disclosures at issue were never confidential to begin with: shared with Adams's wife, with lay members present at the excommunication hearing, and effectively with the public once Adams posted the videos himself. The court did not dispute those facts. It held instead that whether such disclosures counted as "reasonable and necessary" under LDS doctrine was a religious determination the state had no constitutional authority to second-guess.
The question is resolved in Arizona as a matter of constitutional law, not merely statutory interpretation. No Arizona court may examine a religious institution's own classification of what constitutes a protected confidential communication, regardless of how many people were present when it was repeated. The ruling's reach extends beyond this church: Associated Press reporting notes the underlying clergy-privilege statute exists in 33 states, and that the LDS Church, the Catholic Church, Jehovah's Witnesses, and other faiths have lobbied jointly against reform efforts. Coverage of the July 2026 decision notes its First Amendment holding, if it stands, forecloses the legislative fix some reform advocates had proposed: narrowing or removing the clergy exemption from Arizona's mandatory reporting statute. The court's reasoning treats judicial or legislative interference with a church's own doctrinal self-classification as constitutionally impermissible on its face, not merely undesirable as policy.
Julie Doe, now 24, alleges her adoptive father, Craig Ford, began sexually abusing her in December 2015, when she was 15. Her adoptive mother, Jennifer, informed the family's LDS bishop and stake president in Ridgefield, Washington, including disclosing sexual letters Ford had written to the victim and a sex toy he had purchased for her. Ford took Doe to Albany, Oregon in April 2016, where the abuse continued "on an almost daily basis" for several months, according to the complaint. Ford was later convicted of child molestation charges involving a second adoptive daughter in Clark County, Washington (2018), and of incest and rape charges involving Doe in Linn County, Oregon (2021–2022); he is currently serving a 33-year sentence. Doe filed suit against the church on February 10, 2025, seeking $25 million in damages.
Unlike Jensen, Brock, and Adams, the church's defense in this case does not rest on clergy-penitent privilege. The mother's disclosures to clergy were not made in confession. On February 20, 2026, the church filed a Motion for Judgment on the Pleadings arguing Oregon and Washington follow a "no-duty-to-rescue" rule, and in an April 2026 opposition brief its attorneys stated directly that "churches have no legal duty to intervene to prevent a father from abusing his own child." The brief argues the church "would have neither the ability nor responsibility to take reasonable steps... to prevent the [perpetrator] from assaulting his or her own child, even if the [organization] had knowledge of prior assaults." The church separately argues that Oregon's mandatory-reporting statute is criminal, not civil, and "does not create civil liability" for a failure to report, and that its own internal written policy directing leaders to "report the abuse to civil authorities" does not itself create an enforceable legal duty to do so.
On March 13, 2026, the plaintiff moved to amend the complaint, citing internal church records produced in discovery that allegedly show the failure to act reached "headquarters personnel" in Salt Lake City, not only local clergy. In a reply brief filed April 24–25, 2026, the plaintiff's attorneys argued the church misread the Oregon Supreme Court's E.J.T. decision, contending it "only shielded law enforcement agencies from civil suits regarding their own investigations" and "explicitly left open" negligence claims against mandatory reporters, including clergy. Both motions came before Judge Michael J. McShane at a hearing on August 5, 2026; per the court's own docket, they were taken under advisement and remained unresolved as of that date.
The quoted language from the church's opposition brief is drawn from a single outlet's reporting on the filing (The Olympic Herald, an independent Washington news outlet); the underlying 26-page brief was not independently obtained for this entry. Case number, judge, and hearing status are confirmed directly against the federal court's own docket.
The chronology, compressed
CAPTA
Federal Child Abuse Prevention and Treatment Act pushes states toward mandatory reporting laws.
Utah ritual abuse task force
State task force documents generational, familial, and religiously-coded patterns of abuse. Funding for the resulting investigative expertise is cut shortly after.
Richard G. Scott's address
Directs victims to their priesthood leader and frames a "degree of responsibility" a victim may need to recognize.
The help line established
Housed in the church's Office of Risk Management. Routes serious abuse disclosures to Kirton McConkie attorneys.
Michael Jensen, Utah and West Virginia
Reported repeatedly to church leaders over nearly a decade. Settled for nearly $60 million, concealed until 2025.
Susan Brock, Arizona
Two bishops learn of her abuse of a teenage boy, call Kirton McConkie, and do not report. Victim's family goes to police independently. Bishops not charged.
Julie Doe, Washington and Oregon
Abuse begins; disclosed to LDS clergy in Ridgefield, WA. Family relocates to Albany, OR; abuse continues.
Paul Adams confesses to Bishop Herrod
Sworn accounts disagree on the year. Routed through the help line to Kirton McConkie attorney Merrill Nelson. Not reported to police.
Federal arrest, no church assistance
Adams identified and arrested by federal investigators, seven years after the first confession. Dies by suicide in jail before trial.
Trial court finds waiver
Judge Laura Cardinal rules Adams's own public conduct waived his privilege. Reversed on appeal four months later.
Court of Appeals vacates the waiver finding
Panel holds Adams disclosed only the underlying conduct publicly, not the substance of his confession, so no waiver occurred.
Arizona Supreme Court declines further review
Lets the Court of Appeals ruling stand. Church confirmed exempt from disclosing the 2013 excommunication and disciplinary records.
Trial court dismisses on remand
Judge Timothy Dickerson finds no evidence of church knowledge outside the protected communications.
Court of Appeals revives the case
Unanimous panel holds a jury could find the privilege waived by later disclosures to Adams's wife and the disciplinary council.
Arizona Supreme Court, second and final ruling
Reverses the Court of Appeals on First Amendment grounds, joined by Catholic diocesan amici. Holds no court may examine a church's own classification of a confidential communication. Summary judgment for the church reinstated.
Julie Doe, litigation
Suit filed Feb. 2025. Church argues no duty to prevent intrafamily abuse, distinct from the clergy-privilege theory in the other three cases. Motions taken under advisement following an Aug. 5, 2026 hearing; unresolved as of this entry.
What the chronology is for
Courts, where they have jurisdiction, decide individual cases, and the Adams case shows that work can run sixteen years, produce two Arizona Supreme Court opinions, and still end without the children's claim ever reaching a jury. Assembling the chronology here makes the mechanism itself visible: a documented sequence connecting a specific 1992 doctrinal statement, a specific 1995 institutional structure, and specific, dated outcomes in four states, each independently sourced and each still checkable against the public record.
Solutions, where they exist, follow from naming the mechanism precisely enough to be addressed. Legislatively, in how clergy-penitent privilege statutes are written, though the 2026 ruling's First Amendment holding narrows that path considerably. Institutionally, in whether an internal help line reports to risk management or to child welfare professionals. Individually, in what parents are told to expect if they or their children ever need to make that first disclosure.
Sources
- Associated Press, "Mormon Church helpline lets leaders keep sex abuse allegations from police," August 2022 investigation.
- Salt Lake Tribune, "Sex abuse and the LDS Church 'help line': 4 takeaways," August 7, 2022.
- Claims Journal, "Seven Years of Sex Abuse: How Mormon Officials Let it Happen," August 5, 2022.
- Fox 13 Now, "Utah politician, lawyer told LDS bishop not to report abuse, docs show," September 11, 2022, on Merrill Nelson's advisory role.
- "Kirton McConkie," Wikipedia, on the 2022 help line reporting and related litigation.
- Richard G. Scott, "Healing the Tragic Scars of Abuse," General Conference, April 1992, churchofjesuschrist.org.
- Richard G. Scott, "To Heal the Shattering Consequences of Abuse," General Conference, April 2008.
- KUTV, "Six Mormon families suing LDS church over alleged cover up of child sexual abuse," December 2017.
- Washington Post, "Sexual abuse case against Mormon Church begins in West Virginia," January 2018.
- Jane Doe-1 v. Corp. of President of Church of Jesus Christ of Latter-Day Saints, West Virginia Supreme Court of Appeals, 2017.
- FLOODLIT.org, "Christopher Michael Jensen Mormon sex abuse case," March 25, 2025 and April 11, 2025 updates.
- Salt Lake Tribune, "Arizona Supreme Court upholds...," April 11, 2023, on Judge Laura Cardinal's August 8, 2022 waiver ruling and its reversal on appeal.
- The Corporation of the President of the Church of Jesus Christ of Latter-Day Saints v. Hon. Cardinal, Arizona Court of Appeals, Division Two, No. 2 CA-SA 2022-0047, filed December 15, 2022.
- KUER, "Arizona Supreme Court upholds clergy privilege in Mormon help line abuse case," April 11, 2023.
- Deseret News, "Arizona Supreme Court upholds Latter-day Saint priest-penitent privilege in sex abuse case," April 12, 2023.
- Associated Press, "Sex-abuse video victimizes child long after abuser is gone," August 2022, on NCMEC referrals and federal arrest data tied to the Adams video.
- PBS NewsHour / Associated Press, "Lawsuit in Arizona says Utah firm and lawmaker helped Mormons hide abuse," October 12, 2022, on Merrill Nelson and the Kirton McConkie call logs.
- Religion News Service, "Court cites clergy-penitent privilege in dismissing child sex abuse lawsuit against LDS church," November 9, 2023.
- KUER, "Arizona court dismisses child sex abuse suit against the LDS Church," November 8, 2023.
- Bitter Winter, "The Paul Adams Case: Once Again, Courts Protect the Secret of Confession," November 14, 2023, on Judge Timothy Dickerson's November 3, 2023 ruling.
- Arizona Capitol Times, "Appeals court overrules LDS church position, jury needs to hear details of child abuse," July 30, 2025.
- Tucson.com, "Ruling revives lawsuit against LDS church in Bisbee molestation case," July 30, 2025, quoting Judge Christopher P. Staring's opinion for the Court of Appeals and attorney John Trebon.
- Courthouse News Service, "Abuse victims say Mormon bishop neglected duty to report," February 2025, on oral argument and the disputed confession date.
- KJZZ, "Arizona Court of Appeals revives abuse case lawsuit vs. Church of Jesus Christ of Latter-day Saints," July 31, 2025.
- Arizona Mirror, "High court says churches, not judges, define a 'confession' when it comes to reporting child abuse," July 30, 2026, on the Catholic diocesan amicus filings and Cadigan's confidentiality rebuttal.
- AZFamily / 12News, "Arizona Supreme Court sides with LDS Church in 'duty-to-report' abuse case," July 31, 2026.
- BishopAccountability.org, syndicated coverage of the July 2026 ruling.
- Tucson.com / Arizona Daily Star, "Arizona ruling: Religions don't have to report child sex abuse to authorities," coverage of the July 2026 ruling, quoting Justice John Lopez's opinion.
- KGUN9, "Arizona Supreme Court: Clergy not required to report child abuse revealed during confession," coverage of the July 2026 ruling.
- WORLD, "Arizona Supreme Court rules clergy abuse reporting optional," coverage of the July 2026 ruling.
- Justia, Arizona Supreme Court Decisions, Doe v. The Corporation, CV-25-0213-PR (2026).
- Phoenix New Times, "Brocked Up: Supervisor Fulton Brock Attempted to Cover Up the Sexual Liaisons Between His Wife, Daughter and a Teenage Boy," September 2011.
- Phoenix New Times, "Susan Brock Sex Scandal: Chandler Police Recommended LDS Bishops be Charged With Crimes for Failing to Report Abuse," May 2011, on Detective Christopher Perez's report and the Pinal County Attorney's declination.
- East Valley Tribune, "Prosecutors: Susan Brock pursued molested boy's brother first, Mormon church knew of sex," August 2011.
- Ahwatukee Foothills News, "Brock case raises issue of church's role in reporting crime," April 2011.
- WWRN, "Susan Brock molestation case: LDS bishops won't be charged," on the church's public statement and Chandler police's independent report.
- FLOODLIT.org, "Susan Marie Brock Mormon sex abuse case," on sentencing and release dates.
- The Columbian, "Woman files $25M lawsuit against Church of Jesus Christ of Latter-day Saints over abuse by adoptive Ridgefield dad," February 17, 2025.
- KOIN, "Oregon lawsuit alleges LDS Church failed to intervene in child sex abuse case."
- Crew Janci LLP, case summary, "Mormon Church Faces $25M Lawsuit for Failing to Report Child Sexual Abuse in Oregon & Washington."
- The Olympic Herald, "Amended Lawsuit Alleges LDS Church Orchestrated Interstate Child Sex Abuse Cover-Up," March 26, 2026.
- The Olympic Herald, "LDS Church Claims 'No Legal Duty' in Interstate Child Sex Abuse Cover-Up Lawsuit," April 21, 2026.
- The Olympic Herald, "Plaintiff Rebukes LDS Church's 'No Legal Duty' Defense in Interstate Abuse Lawsuit," April 25, 2026.
- Doe v. Corporation of The Presiding Bishop of the Church of Jesus Christ of Latter-Day Saints et al., U.S. District Court, District of Oregon, Case No. 6:25-cv-00222, docket entry 73, motion hearing minutes, August 5, 2026.