If you were sexually abused as a child by a priest or other clergy member in Arizona, you can bring an Arizona priest sexual abuse lawsuit against the abuser and, in many cases, the diocese or religious institution that employed them, provided you file before your 30th birthday under the state’s 2019 Child Victims Act. A separate one-time “lookback” window that revived older, time-barred claims closed on December 31, 2020. Suits brought today against institutions still face a higher burden of proof than ordinary civil cases, and an active fight over clergy-penitent privilege is shaping what evidence a jury is allowed to hear.
Who Can Sue and By When
Arizona House Bill 2466, signed by Governor Doug Ducey in May 2019, extended the civil statute of limitations for childhood sexual abuse. Survivors previously had only two years after turning 18 to sue. The Child Victims Act gives them twelve years, meaning claims can be filed up to age 30.1Arizona Legislature. HB 2466
The same law opened a one-time lookback window that let adult survivors file claims that had already expired under the old deadline. That window ran through December 31, 2020, and is now closed.2Arizona Mirror. Legislature Unanimously Approves Sexual Abuse Bill, Breaks Budget Logjam A civil lawsuit is a different track from criminal charges, which carry their own deadlines; several high-profile Arizona cases, including the 2001 arrest of Monsignor Robert C. Trupia on seven felony counts, collapsed when the criminal statute of limitations had already run.3Tucson.com. Monsignor Robert C. Trupia and the Tucson Diocese Scandal
What You Have to Prove Against a Diocese or Church
Suing the individual abuser is one thing. Suing the diocese, parish, school, or church that placed them is often where the real money is, and Arizona law makes institutional claims harder than ordinary negligence suits.
For claims against non-perpetrators such as dioceses or schools, a plaintiff must show the institution had actual notice or knowledge of the risk of abuse.4Arizona Legislature. HB 2466 Senate Engrossed Summary A diocese that quietly transferred an accused priest to a new parish, for example, is the kind of fact pattern that supports institutional liability. Former Phoenix Bishop Thomas J. O’Brien publicly admitted in a 2003 immunity agreement with the Maricopa County Attorney’s Office that he knew of abuse accusations against priests and transferred them to new assignments without warning their new supervisors or parishioners.5CBS News. Phoenix Bishop Makes a Deal
Claims that were filed under the revived-claim lookback window carry two extra hurdles. Plaintiffs must prove their case by “clear and convincing evidence,” a higher bar than the normal civil preponderance standard, and punitive damages are not available on those revived claims.2Arizona Mirror. Legislature Unanimously Approves Sexual Abuse Bill, Breaks Budget Logjam Those limits were the compromise that got the bill unanimously through the legislature.
The Clergy-Penitent Privilege Fight
Whether a diocese or church can be held responsible for failing to act on an abuse disclosure often depends on a question Arizona courts are still answering: does clergy-penitent privilege shield what a bishop or priest was told?
The case driving this question is not Catholic. In 2011, Paul Douglas Adams, a Border Patrol employee in Bisbee, confessed to his Church of Jesus Christ of Latter-day Saints bishop that he was sexually abusing his five-year-old daughter. Bishop John Herrod called the LDS Church’s internal help line, routed to the law firm Kirton McConkie, and was told he could not report the abuse. A later bishop was told about the abuse in 2012 and also did not report. The abuse continued; Adams began assaulting a second infant daughter in 2015, six weeks after her birth, and was arrested only in 2017 after New Zealand authorities discovered videos he had posted online. He died by suicide in custody.6AP Images Blog. Seven Years of Sex Abuse: How Mormon Officials Let It Happen7Floodlit.org. Paul Douglas Adams Case
Three of Adams’ children sued the LDS Church and the two bishops in 2020. A Cochise County judge dismissed the case in 2023, ruling that the bishops’ knowledge was shielded by clergy-penitent privilege. On July 29, 2025, an Arizona Court of Appeals panel unanimously reversed and sent the case back for trial. The appellate judges held that a jury should decide whether Adams’s disclosures were actually protected confessions, pointing to the fact that his wife was present when he repeated the confession to his bishop and that non-clergy members attended his 2013 excommunication hearing where he again admitted the abuse. The court also noted that the LDS Church’s own handbook permits bishops to report when “disclosure is necessary to prevent life threatening harm or serious injury.”8Arizona Capitol Times. Appeals Court Overrules LDS Church Position, Jury Needs to Hear Details of Child Abuse9Axios. Mormon Sex Abuse Reporting Clergy Privilege Lawsuit Arizona
The church has said it will appeal to the Arizona Supreme Court, which accepted the petition as Case No. CV-25-0213-PR.10Arizona Courts. Jane Doe I et al. v. Corporation of the President of the Church of Jesus Christ of Latter-day Saints How the state’s highest court rules will directly affect whether survivors in future lawsuits can use what clergy knew as evidence.
Mandatory Reporting and the Clergy Exemption
Arizona statute A.R.S. § 13-3620 lists clergy among the professionals who must immediately report suspected child abuse to law enforcement, the Department of Child Safety, or a tribal agency. Failing to report a sex-related offense is a Class 6 felony.11Arizona Legislature. A.R.S. § 13-3620
The statute carves out an exemption, though. Clergy may withhold reporting of a “confidential communication or a confession” if they determine it is “reasonable and necessary within the concepts of the religion.” The exemption covers only communications, not a clergy member’s own observations of a child. Arizona’s mandatory-reporter training materials note that the presence of a third party during the communication may void the privilege, which is the opening the Court of Appeals seized on in the Adams case.12Arizona Department of Child Safety. Mandated Reporter Training: Religions Overview
State Senator Victoria Steele has introduced legislation since 2020 to remove the clergy exemption. Her Senate Bill 1008 in 2021 would have required clergy of all faiths to report suspected abuse without a confessional carve-out, but the bill was never granted a hearing, as was true of an identical bill the year before.13Arizona Mirror. Bill Would Eliminate Clergy Privilege, Require Reporting of Child Abuse The exemption remains in Arizona law.14Arizona Legislature. A.R.S. § 13-3620
What Arizona Lawsuits Have Produced
Arizona survivors have won large recoveries from each of the state’s three Catholic dioceses, often through bankruptcy proceedings forced by a wave of claims.
Tucson Diocese
The Diocese of Tucson became one of the first in the country to file Chapter 11 over clergy abuse, filing on September 20, 2004, with more than 50 abuse claims pending. Its bankruptcy plan, confirmed on August 1, 2005, produced a $22.2 million settlement. Payments to individual survivors ranged from $15,000 to $600,000 depending on severity, with 14 of the most severely affected survivors each receiving at least $200,000.15Reveal. Catholic Dioceses Declare Bankruptcy on Eve of Sexual Abuse Trials Before bankruptcy, the diocese had already paid $14 million in January 2002 to settle claims from 10 men who said they were abused by local priests in the 1960s, 1970s, and 1980s.3Tucson.com. Monsignor Robert C. Trupia and the Tucson Diocese Scandal Its published list of credibly accused personnel includes more than 40 names.16Diocese of Tucson. Credibly Accused
Gallup Diocese
The Diocese of Gallup, which serves parishioners in parts of Arizona and New Mexico including several Native American reservations, filed Chapter 11 in November 2013. A reorganization plan approved in June 2016 provided about $22 million to 57 claimants, funded by insurance, parish contributions, sales of diocesan property, and contributions from other dioceses, including $300,000 from the Diocese of Phoenix. The settlement also required the diocese to publicly list credibly accused priests for at least ten years, prohibit confidentiality clauses in future settlements unless the survivor requests one, and have the bishop personally sign apology letters.17Diocese of Gallup. Chapter 11 Settlement
Phoenix Diocese
A Maricopa County grand jury indicted six Phoenix-area priests in 2003 after a yearlong investigation.18New York Times. Bishop of Phoenix Admits Transfers of Accused Priests The Diocese of Phoenix has publicly identified 43 clergy it considers credibly accused of abuse since its founding in 1969, and an advocacy group released a broader list in June 2019 naming 109 clerics connected to the diocese.19ABC15. Group to Release Names of 109 Clerics Accused of Sexual Abuse in Diocese of Phoenix High-profile Phoenix cases have included Father Jack Spaulding, removed from ministry in 2011 and indicted in January 2020 on six counts of sexual misconduct with a minor and one count of child molestation before he died in February 2020,20Maricopa County Attorney’s Office. Spaulding Indictment and Joseph Henn, a former Salvatorian priest at St. Mark Parish, indicted in 2003 on 13 counts of child sexual molestation involving at least three boys under 15, who fled to Italy and was finally returned to Arizona in 2019.21The Catholic Spirit. Former Priest Arrested in Italy, Extradited to Arizona, Formally Arraigned
Lookback Window Lawsuits
The 2019–2020 lookback window produced a new round of filings against the Diocese of Phoenix even as the main diocesan bankruptcies were long settled.
In November 2020, Annette Slade sued the diocese alleging sexual abuse by a music teacher at St. Thomas the Apostle School in Phoenix around 1970. A plaintiff identified as John RJ Doe filed a separate suit alleging abuse by a Eucharistic minister at St. William’s Parish in Cashion between 1984 and 1986.22Anderson Advocates. Two Lawsuits Filed Against Diocese of Phoenix Under Arizona Child Victims Act On November 23, 2020, a plaintiff identified as Jane CE Doe filed suit alleging abuse by Father Jorge Washington Cordova, who recruited young women and children into a group called “Las Consecradas” while serving in Phoenix in the 1990s. The complaint alleged that the plaintiff’s mother reported the abuse to a diocesan chancellor around 1993 and was told she would get a “reputation” if she pursued the complaint. Cordova was later criminally charged in Yuma and Maricopa counties, fled to Ecuador, and died in 2018.23Anderson Advocates. Fugitive Phoenix Priest and Leader of Las Consecradas Named in Sexual Abuse Lawsuit
A 2020 Maricopa County lawsuit on behalf of a Navajo man also illustrated how the lookback window reached beyond Arizona defendants. The suit, filed against the Diocese of Phoenix, the Diocese of Lafayette in Indiana, and Father James Grear, alleged that Grear began repeatedly abusing the plaintiff in 1977 when the plaintiff was 14 and Grear was an administrator at Chinle High School on the Navajo Nation, and that both dioceses knowingly assigned Grear to Native communities despite his history.24AZ Central. Lawsuit Says Catholic Church Moved Priest James Grear to Arizona Schools Knowing Abuse Claims
If You Still Have Time to File
If you are under 30 and were abused as a child by clergy in Arizona, the normal civil deadline under HB 2466 still applies to you.1Arizona Legislature. HB 2466 If you are older than 30 and did not file by December 31, 2020, the lookback window has closed and your claim may be time-barred unless new legislation reopens it. An attorney who handles clergy abuse cases can tell you where your particular facts fall, especially where institutional conduct, out-of-state defendants, or disputed privilege questions are in play.