State Court Activity
Active filings in Missouri, California, New York under revived SOL statutes
Institutional Abuse · civil actions arising from sexual abuse allegations and institutional concealment within churches
Defendant
Roman Catholic Bishop of Springfield
MDL / Track
See litigation status
E.D. La. (Bankruptcy)
Judge
Judge Meredith Grabill
Plaintiffs
500+ claims (New Orleans settlement)
Bellwether / Trial
Settlement Status
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Case overview
The Archdiocese of New York agreed in December 2025 to mediate 1,300 sexual abuse claims spanning 1952 to 2020, with retired Los Angeles County Superior Court Judge Daniel Buckley presiding. The archdiocese has put real estate assets up for sale to raise $300 million toward potential settlement, while facing parallel coverage litigation with Chubb Insurance Companies over pre-2000 policies. Civil trials were scheduled for 2026 before the mediation pause.
Causation Theory
Clergy sexual abuse causes distinct "Spiritual Harm" compounding conventional trauma, per a 2025 PLOS ONE systematic scoping review (Durkin et al., DOI 10.1371/journal.pone.0317821) and a July 2025 Journal of Religion and Health systematic review. Survivors experience: (1) betrayal of pre-abuse trust in clergy as moral authorities; (2) alterations in religious practices and beliefs in God/Church; and (3) psychological sequelae including PTSD, depression, and disrupted interpersonal functioning. The mechanism is institutional betrayal layered onto interpersonal abuse, with disclosure often met by church-imposed "forgiveness" protocols that re-traumatize victims and enable continued access to children.
Litigation status
The New Orleans Archdiocese bankruptcy settlement received final approval December 2025 from U.S. Bankruptcy Judge Meredith Grabill, establishing a $230 million fund for hundreds of survivors. The Roman Catholic Diocese of Rockville Centre Chapter 11 proceedings saw appellate activity in S.D.N.Y. before Judge J. Paul Oetken, who affirmed dismissal of claims for failure to state a claim under federal pleading standards. Federal district courts in Missouri and California continue to see new filings and removal practice disputes.
State Court Activity
Active filings in Missouri, California, New York under revived SOL statutes
Geographic exposure
Catholic Church: $3.6B paid in U.S. settlements 2004-2023 per Georgetown University Center for Applied Research in the Apostolate. LDS/Mormon Church: 91+ California cases; Arkansas state court actions with pending SOL validity. Protestant/evangelical: OALC (Minnesota), Golden Dawn (Arizona), First Assembly of God (Arkansas) emerging as new fronts. Total affected population: thousands of survivors across Catholic dioceses (Santa Fe 400+ claims; Las Cruces 8 new); LDS cases in California and Arkansas (100+); OALC unknown but 33 congregations with insular reporting barriers.
Pulaski County Circuit Court. Pinnacle Mountain Ward LDS Church, 600 S. Rodney Parham Rd., Little Rock. Plaintiff 'J.H.' alleges 12 years of abuse by stepfather 'G.S.' in position of 'high spiritual authority.' Filed Jan. 30, 2026 under Justice for Vulnerable Victims of Sexual Abuse Act, Ark. Code 16-118-118 (SOL window closed Jan. 31, 2026; validity pending Arkansas Supreme Court review). Also invokes Delayed Discovery Act, Ark. Code 16-56-130. Three church suits filed simultaneously in Little Rock including North Little Rock First Assembly of God and Our Lady of the Holy Souls Catholic School (Diocese of Little Rock).
91 cases filed across 26 counties including Alameda, Contra Costa, Del Norte, Fresno, Kern, Lassen, Los Angeles, Napa, Orange, Placer, Riverside, Sacramento, San Bernardino, San Diego, San Joaquin, San Luis Obispo, San Mateo, Santa Clara, Shasta, Solano, Sonoma, Stanislaus, Tulare, Ventura, Yuba. Modesto case specifically identified. Slater Slater Schulman representing. Venue battle: church sought federal court; plaintiffs secured state court consolidation. Alleged cover-up using $200B+ in assets, $7B annual tithing. Defendants include teachers, missionaries, priests, bishops.
3rd Judicial District Court (Las Cruces). Eight new lawsuits filed Feb. 2026 against Roman Catholic Diocese of Las Cruces and Catholic Diocese of El Paso. Parishes: Our Lady of Health (Las Cruces), Our Lady of Purification (Doña Ana), Immaculate Conception (Alamogordo), Our Lady of Guadalupe (Tortugas Pueblo, Mesilla Park), St. Anthony (Anthony), St. Eleanor (Ruidoso). Priests Bernard Bissonnette and David Holley linked to Servants of the Paraclete Center, Jemez Springs. Follows Archdiocese of Santa Fe $121M bankruptcy settlement (2022) covering nearly 400 claims.
Old Apostolic Lutheran Church (OALC), Woodland Park congregation north of Duluth. Daryl Bruckelmyer, preacher/leader. James Massie pleaded guilty Dec. 2024 to four counts felony criminal sexual conduct with victims under 13; sentenced March 2025 to 7.5 years. Church 'forgiveness sessions' allowed continued access to victims. 33 OALC churches in U.S./Canada. No central headquarters. Multiple pending civil lawsuits.
Golden Dawn Tabernacle/Tabernaculo Emanuel, Tucson. Pastor Isaac Noriega. Decades-long cover-up of child sexual abuse allegations. 'The Message' sect (William Branham). No statute of limitations for felony sexual assault under Arizona law. Former members describe 'cult' environment with medical isolation, shunning of victims. Allegations against pastor's son Stephen Noriega for unwanted physical contact with children.
Key defendants
Roman Catholic Bishop of Springfield
Role: Diocesan Corporation Sole
Mass. SJC 2022 ruling: charitable immunity bars negligent hiring/supervision claims but not direct assault counts; church autonomy defense rejected for interlocutory appeal. Exposure remains on intentional tort theories.
International Churches of Christ, Inc.
Role: Parent Religious Organization
C.D. Cal. 2022 complaint (Case No. 22-09467) alleges RICO enterprise liability for systemic child sexual abuse; co-defendant Hope Worldwide and Mercy Worldwide named as operational arms. Aggressive organizational liability theory.
Corporation of the President of the Church of Jesus Christ of Latter-Day Saints
Role: Parent Religious Corporation
D.N.M. 2023 ruling (Civ. No. 20-318): vicarious liability dismissed but direct negligence claim survives summary judgment; punitive damages barred. Pattern of successful statute-of-limitations defenses in Utah (Doe v. COP, 2004 UT App 274) and New Mexico.
| Defendant | Role | Intelligence Note |
|---|---|---|
| Roman Catholic Bishop of Springfield | Diocesan Corporation Sole | Mass. SJC 2022 ruling: charitable immunity bars negligent hiring/supervision claims but not direct assault counts; church autonomy defense rejected for interlocutory appeal. Exposure remains on intentional tort theories. |
| International Churches of Christ, Inc. | Parent Religious Organization | C.D. Cal. 2022 complaint (Case No. 22-09467) alleges RICO enterprise liability for systemic child sexual abuse; co-defendant Hope Worldwide and Mercy Worldwide named as operational arms. Aggressive organizational liability theory. |
| Corporation of the President of the Church of Jesus Christ of Latter-Day Saints | Parent Religious Corporation | D.N.M. 2023 ruling (Civ. No. 20-318): vicarious liability dismissed but direct negligence claim survives summary judgment; punitive damages barred. Pattern of successful statute-of-limitations defenses in Utah (Doe v. COP, 2004 UT App 274) and New Mexico. |
Timeline
First Known LDS Abuse Lawsuit Filed
Victim's mother files personal injury lawsuit in Maricopa County Superior Court against Kenneth Ray and LDS Church, establishing earliest documented church sexual abuse litigation. Case settled 1990 for undisclosed amount. Contradicts 2012 sworn testimony by church Risk Management Director Paul Rytting claiming first suit filed in 1989.
Jeremiah Scott Files Suit Against LDS Church
Plaintiff alleges church retained Franklin Curtis in leadership positions despite prior abuse accusations, enabling continued access to children. Curtis case later settled 2001 for $3 million.
West Virginia Families File Major Coverup Suit
Six families sue LDS Church and local leaders in West Virginia state court, alleging negligence and conspiracy in failure to warn about Michael Jensen's abuse of at least 20 children spanning 2004-2013. Jensen convicted February 2013.
$32 Million Mid-Trial Settlement in West Virginia
LDS Church settles West Virginia abuse litigation for $32 million after spending $27 million in legal fees over five years. Total expenditure reaches $59 million. Church subsequently sues insurers 2021 seeking reimbursement beyond $15 million self-insured retention.
California Litigation Surge: ~100 Lawsuits Filed
Nearly 100 civil lawsuits filed in California against LDS Church alleging sexual abuse and institutional failure to protect victims, capitalizing on revived statute of limitations. FLOODLIT.org documents surge beginning August 2024.
FLOODLIT Database Surpasses 1,000 Documented Cases
Non-profit investigation documents over 1,000 cases of sexual abuse or other sex crimes involving LDS church members. Database later expands to 4,050+ reports with $51 million in documented settlements across 15 cases.
West Virginia Insurance Litigation Reveals Scale
Court records disclose LDS Church cited 378 settlement payments for sexual abuse or other injuries from 2006-2012 in insurance coverage dispute. Church sought reimbursement for defense costs and $32 million settlement.
Statute of limitations
Search results conflate Catholic/clergy abuse with LDS-specific litigation (MDL 3102, MTC cases). No reliable 2026 data on active Catholic church abuse SOL windows beyond CA AB 2777. Intake operations must verify: (1) AB 2777 applicability to institutional defendants—source [1] cites general adult sexual assault window but institutional coverage unclear; (2) NY CVA/ASA windows expired—no current revival; (3) Georgia Hidden Predator Act revival window closed 2022. Prioritize CA intakes before Dec. 31, 2026 deadline. Cross-check all revival statutes against current legislative databases—reform momentum continues but windows are time-limited.
⚠California
10 years from incident or 3 years from discovery, whichever is later
Rule: AB 2777 creates three-year lookback window for adult sexual assault claims: Jan. 1, 2023 – Dec. 31, 2026
Discovery: 3 years from discovery for adult survivors; 5 years from discovery for childhood claims
AB 2777 window closes Dec. 31, 2026. Prior child revival window (AB 218) expired 2022. Treble damages available for institutional cover-up.
New York
Until age 55 for childhood claims
Rule: Child Victims Act extended SOL to age 55; Adult Survivors Act created temporary lookback window
Discovery: N/A
CVA revival window expired Aug. 14, 2021. ASA revival window expired Nov. 24, 2024. No current revival window active per search results.
Maryland
No statute of limitations
Rule: 2023 law eliminated all civil SOL for child sexual abuse claims
Discovery: N/A
Most favorable SOL environment for child sex abuse litigation nationwide. Applies to all defendants including institutions.
Florida
No civil SOL for abuse under age 16
Rule: Florida Statute eliminates civil statute of limitations when survivor was under 16 at time of abuse
Discovery: N/A
Adult claims generally 2 years from injury or discovery. No revival window cited.
Texas
Until age 48 for childhood claims (30 years after age 18)
Rule: Texas Civ. Prac. & Rem. Code § 16.0045(a); 5 years for adult claims
Discovery: N/A
SOL applies to all defendants including churches and schools. No revival window. Grade reduced due to lack of retroactive relief.
Georgia
Until age 23 for childhood claims; 2 years from discovery if under 30
Rule: Hidden Predator Act; 2-year revival window expired 2022
Discovery: 2 years from discovery for survivors under age 30 who realize abuse impact later
2020 amendment created 2-year revival window—expired. Legislative efforts ongoing for expanded SOL and additional revival periods.
Connecticut
No time limit if abuser convicted; otherwise 2 years
Rule: Conn. Gen. Stat. § 52-577e; no SOL if criminal conviction obtained
Discovery: N/A
Favorable for claims against third parties based on negligence per Doe v. Boy Scouts of Am. Corp., 147 A.3d 104.
| State | SOL | Rule | Discovery Rule | Notes |
|---|---|---|---|---|
| ⚠California | 10 years from incident or 3 years from discovery, whichever is later | AB 2777 creates three-year lookback window for adult sexual assault claims: Jan. 1, 2023 – Dec. 31, 2026 | 3 years from discovery for adult survivors; 5 years from discovery for childhood claims | AB 2777 window closes Dec. 31, 2026. Prior child revival window (AB 218) expired 2022. Treble damages available for institutional cover-up. |
| New York | Until age 55 for childhood claims | Child Victims Act extended SOL to age 55; Adult Survivors Act created temporary lookback window | N/A | CVA revival window expired Aug. 14, 2021. ASA revival window expired Nov. 24, 2024. No current revival window active per search results. |
| Maryland | No statute of limitations | 2023 law eliminated all civil SOL for child sexual abuse claims | N/A | Most favorable SOL environment for child sex abuse litigation nationwide. Applies to all defendants including institutions. |
| Florida | No civil SOL for abuse under age 16 | Florida Statute eliminates civil statute of limitations when survivor was under 16 at time of abuse | N/A | Adult claims generally 2 years from injury or discovery. No revival window cited. |
| Texas | Until age 48 for childhood claims (30 years after age 18) | Texas Civ. Prac. & Rem. Code § 16.0045(a); 5 years for adult claims | N/A | SOL applies to all defendants including churches and schools. No revival window. Grade reduced due to lack of retroactive relief. |
| Georgia | Until age 23 for childhood claims; 2 years from discovery if under 30 | Hidden Predator Act; 2-year revival window expired 2022 | 2 years from discovery for survivors under age 30 who realize abuse impact later | 2020 amendment created 2-year revival window—expired. Legislative efforts ongoing for expanded SOL and additional revival periods. |
| Connecticut | No time limit if abuser convicted; otherwise 2 years | Conn. Gen. Stat. § 52-577e; no SOL if criminal conviction obtained | N/A | Favorable for claims against third parties based on negligence per Doe v. Boy Scouts of Am. Corp., 147 A.3d 104. |
Live intelligence
AI litigation brief
Church Abuse remains active litigation category with 13 current signals in the accepted feed.
Overview
The New Orleans Archdiocese bankruptcy settlement received final approval December 2025 from U.S. Bankruptcy Judge Meredith Grabill, establishing a $230 million fund for hundreds of survivors. The Roman Catholic Diocese of Rockville Centre Chapter 11 proceedings saw appellate activity in S.D.N.Y. before Judge J. Paul Oetken, who affirmed dismissal of claims for failure to state a claim under federal pleading standards. Federal district courts in Missouri and California continue to see new filings and removal practice disputes.
Key developments
Trajectory
Press coverage is active for Church Abuse. Court-side confirmation through state civil actions, bankruptcy venues, and attorney-general investigations is the next escalation check.
Editorial intelligence
Editorial coverage should stay tied to source-backed developments and avoid placeholder status copy for Church Abuse.
Generated Apr 28, 2026, 12:00 AM UTC
13 events detected
Google News (13)
Albany diocese settles hundreds of child sexual abuse cases - WAMC
Albany diocese settles hundreds of child sexual abuse cases - WAMC
Trinity Church Denies All Wrongdoing in Child Abuse Lawsuit (again) - rocketcitynow.com
Catholic Church Sexual Abuse Crisis | Cases, Scandal, United States, Ireland, & Facts - Britannica
Archbishop offers pastoral message on clergy abuse, outlines stronger protections - Detroit Catholic
Diocese of El Paso declares bankruptcy to settle abuse claims filed under New Mexico lookback law - OSV News
Diocese of El Paso declares bankruptcy to settle abuse claims filed under New Mexico lookback law - OSV News
New York AG sues Catholic Diocese of Buffalo over sexual abuse allegations - ABC News - Breaking News, Latest News and Videos
New York AG sues Catholic Diocese of Buffalo over sexual abuse allegations - abcnews.com
New York AG sues Catholic Diocese of Buffalo over sexual abuse allegations - abcnews.com
Brooklyn Diocese seeks settlement of 1,100 clergy abuse lawsuits under Child Victims Act - National Catholic Reporter
Brooklyn Diocese seeks settlement of 1,100 clergy abuse lawsuits under Child Victims Act - National Catholic Reporter
Diocese of Brooklyn enters into mediation to resolve 1,100 abuse claims - OSV News
No recent PubMed signals. Monitoring is active — this section updates automatically.
No recent court filing signals. Monitoring is active — this section updates automatically.
No recent legislative signals. Monitoring is active — this section updates automatically.
Audit normalization notes
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LexGenius Ranking
56Score
Activity volume is building across tracked sources
Monitoring
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Last: Apr 28, 2026, 12:00 AM UTC
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PACER
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Google News
PubMed
Event feed
13
events detected
AI Brief
Church Abuse remains active litigation category with 13 current signals in the accepted feed.
Overview
The New Orleans Archdiocese bankruptcy settlement received final approval December 2025 from U.S. Bankruptcy Judge Meredith Grabill, establishing a $230 million fund for hundreds of survivors. The Roman Catholic Diocese of Rockville Centre Chapter 11 proceedings saw appellate activity in S.D.N.Y. before Judge J. Paul Oetken, who affirmed dismissal of claims for failure to state a claim under federal pleading standards. Federal district courts in Missouri and California continue to see new filings and removal practice disputes.
Key developments
WAMC news on Mar 27: Albany diocese settles hundreds of child sexual abuse cases - WAMC.
Generated Apr 28, 2026, 12:00 AM UTC