State Court Activity
90+ lawsuits in California JCCP; additional cases in Utah state court (Salt Lake County Third Judicial District)
Institutional Abuse · civil actions alleging abuse and institutional failures within LDS-affiliated settings
Defendant
The Church of Jesus Christ of Latter-Day Saints
MDL / Track
MDL No. 3150
JPML (denied)
Judge
Judge Karen K. Caldwell
Plaintiffs
ACTIVE
Bellwether / Trial
Settlement Status
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Case overview
The U.S. Judicial Panel on Multidistrict Litigation denied MDL consolidation for LDS sexual abuse litigation in April 2025, finding claims too fact-specific for centralized treatment. California maintains a Judicial Council Coordination Proceeding (JCCP) consolidating state-court cases under a single judge for pretrial discovery. Hundreds of survivors have filed suit alleging the Church of Jesus Christ of Latter-day Saints operated a systemic cover-up through its 1995-established "Helpline," which routed abuse reports to church risk management attorneys rather than law enforcement.
Causation Theory
Plaintiffs allege the LDS Church's Helpline—operated through its Office of Risk Management, not family services—created a mechanism for concealing abuse by directing bishops to Kirton McConkie attorneys under claims of attorney-client privilege, bypassing mandatory reporting. Sealed records from West Virginia litigation obtained by AP show the Helpline tracks all sex abuse lawsuits against the church and that risk management officials offered $300,000 nondisclosure agreements to silence survivors. The clergy-penitent privilege in more than half of U.S. states provides a statutory loophole that plaintiffs argue the church exploits to avoid disclosure.
Litigation status
The Judicial Panel on Multidistrict Litigation denied MDL consolidation on April 3, 2025, finding case-specific factual issues precluded centralized management under 28 U.S.C. § 1407. Order signed by Judge Karen K. Caldwell. Litigation proceeds through state-level coordination in California and individual federal actions nationwide.
State Court Activity
90+ lawsuits in California JCCP; additional cases in Utah state court (Salt Lake County Third Judicial District)
Geographic exposure
FLOODLIT database documents 4,050+ LDS abuse reports nationwide. No MDL established; JPML denied transfer April 2025. California lookback window driving 90+ filings. Documented settlements exceed $53 million across 30+ cases per Floodlit May 2025 reporting.
California Judicial Council Coordination Proceedings (JCCP) consolidates LDS abuse cases under single judge for pretrial discovery. At least 91 lawsuits filed under California's lookback window, including five San Diego County cases (Imperial Beach ward, San Diego South Stake 1961-1970, Oceanside bishop assault 1995). JPML denied MDL transfer April 3, 2025 (MDL-3150); cases proceed in Central, Eastern, Northern, and Southern Districts of California. Slater Slater Schulman LLP represents 42 of 51 federal actions. Docket: JPML MDL-3150 order denying transfer filed April 3, 2025.
Maricopa County Superior Court: 1984 lawsuit against Kenneth Ray and LDS Church established early pattern of church knowledge of abuse; Ray admitted to bishops from 1968, church failed to report. Bisbee ward cases: Adams family children alleged seven years of abuse with church help line directing bishops not to report. Arizona Court of Appeals case: Church of Jesus Christ of Latter-Day Saints v. Superior Court of Arizona, Maricopa County.
Fruit Heights/Kaysville: Alan Bassett case—over 80 victims came forward; Bassett held multiple LDS callings 1978-2024 including ward clerk, scout leader, technology specialist. 2019 civil lawsuit dismissed without prejudice; June 2024 criminal charges. Davis County records show 1989 non-prosecution agreement for 1978-1989 sexual activities. FLOODLIT database documents 419 Utah cases including Provo MTC (Joseph Bishop), BYU, and multiple ward/stake leadership positions.
Western District of Washington: Bussey v. The Church of the Latter-Day Saints, C.A. No. 2:25-00197. Four plaintiffs allege convicted sex abuser made ward Santa, distributed candy, drove children to activities, assisted scout projects.
District of Nevada: Zimmerman v. The Church of Jesus Christ of Latter-Day Saints, C.A. No. 2:25-00206. Individual federal case.
Northern District of Illinois: Peterson v. The Church of the Latter-Day Saints, C.A. No. 1:25-00947. One of five actions pending outside California in JPML consideration.
Western District of Louisiana: Avery v. The Church of Jesus Christ of Latter-Day Saints, C.A. No. 2:24-01516. Individual federal case.
Northern District of New York: Kitler, et al. v. The Church of Jesus Christ of Latter-Day Saints, C.A. No. 1:24-01071. Church proposed NDNY as alternative MDL transferee district; JPML rejected.
Key defendants
The Church of Jesus Christ of Latter-Day Saints
Role: Institutional Defendant
Defending TVPRA and state-law abuse claims in N.D.N.Y. (1:24-cv-01071). Tolling agreement executed with plaintiffs; individual church officers not bound. First Amendment dismissal strategy failed in Herrera (D.N.M. 20-318) where court recognized direct negligence duty; monitor for appeal posture.
Corporation of the President of the San Diego California Stake - The Church of Jesus Christ of Latter-Day Saints
Role: Local Corporate Entity
Named in Riverside County state-court abuse litigation (Second Amended Complaint, Dec. 2022). California corporate structure creates separate jurisdictional hook; potential indemnity friction with Utah parent entity.
Ronald Boyce
Role: Individual Perpetrator
Primary abuser in N.D.N.Y. case; moved to dismiss as time-barred. No apparent indemnification from institutional defendants; personal exposure on TVPRA and intentional tort claims.
| Defendant | Role | Intelligence Note |
|---|---|---|
| The Church of Jesus Christ of Latter-Day Saints | Institutional Defendant | Defending TVPRA and state-law abuse claims in N.D.N.Y. (1:24-cv-01071). Tolling agreement executed with plaintiffs; individual church officers not bound. First Amendment dismissal strategy failed in Herrera (D.N.M. 20-318) where court recognized direct negligence duty; monitor for appeal posture. |
| Corporation of the President of the San Diego California Stake - The Church of Jesus Christ of Latter-Day Saints | Local Corporate Entity | Named in Riverside County state-court abuse litigation (Second Amended Complaint, Dec. 2022). California corporate structure creates separate jurisdictional hook; potential indemnity friction with Utah parent entity. |
| Ronald Boyce | Individual Perpetrator | Primary abuser in N.D.N.Y. case; moved to dismiss as time-barred. No apparent indemnification from institutional defendants; personal exposure on TVPRA and intentional tort claims. |
Timeline
First Known LDS Sex Abuse Lawsuit Filed
Victim's mother files personal injury suit in Maricopa County Superior Court against Richard Kenneth Ray and LDS Church, alleging negligent counseling and failure to report abuse. Case settles 1990 for undisclosed amount. Contradicts 2012 sworn testimony by church risk management director Paul Rytting that first suit was 1989.
Jeremiah Scott Sues Over Franklin Curtis Abuse
Scott files lawsuit alleging LDS Church kept Curtis in leadership despite prior accusations, enabling child abuse. Part of pattern of church handling accusations internally rather than reporting to authorities.
Missionary Abuse Settlement Reached
LDS Church settles lawsuit from former missionary alleging sexual abuse by mission president in 1980s. Raises questions about church's handling of abuse reports.
West Virginia Families Sue Over Michael Jensen Cover-Up
Six families file negligence and conspiracy suit in West Virginia against LDS Church and local leaders over serial child abuser Michael Jensen. Church spends $27 million in legal fees before $32 million mid-trial settlement in 2018—largest known payout.
Joseph Bishop MTC Abuse Lawsuit Filed
McKenna Denson sues former Missionary Training Center president Joseph L. Bishop and LDS Church, alleging 1980s rape and subsequent cover-up. Draws national attention to church's institutional response protocols.
Church Sues Insurers Over West Virginia Costs
LDS Church sues two insurance companies seeking reimbursement for $59 million total spent on West Virginia defense and settlement. Insurers deny coverage citing failure to give proper notice.
California Lawsuit Wave Begins
Nearly 100 civil lawsuits filed in California against LDS Church under temporary revival window, alleging sexual abuse and failure to protect. Filings span 26 counties including Sacramento, Fresno, Modesto.
MDL Consolidation Denied
Federal judges reject defense motion to consolidate federal LDS abuse cases into multidistrict litigation, ruling cases too dissimilar. Decision preserves individual plaintiff control over filings.
Statute of limitations
Federal preemption not applicable. Cross-jurisdictional screening critical: Utah's restrictive third-party SOL (age 22) drives forum shopping. No active MDL for LDS-specific abuse litigation per search results; cases proceed as individual actions. Search results confirm LDS Church has engaged in confidential settlements to address claim volume.
Utah
No limit for perpetrators; age 22 for non-perpetrators (4 years after majority)
Rule: Utah Code § 78B-2-308: direct claims against abusers have no SOL; third-party claims must file by age 22 or within 4 years of discovery after age 18, whichever is later
Discovery: 4-year discovery period after age 18 applies only to non-perpetrator claims; narrowly construed to require total repression of memory per Colosimo v. Roman Catholic Bishop, 156 P.3d 806 (Utah 2007)
Revival window for claims time-barred as of July 1, 2016: 35 years from 18th birthday or 3 years from discovery, whichever is later; excludes claims litigated to finality or settled (unless fraud/duress)
California
Age 40 or 5 years from discovery, whichever is later; revival window closed
Rule: AB 218 three-year revival window (2019-2022) expired December 31, 2022; no current open window for time-barred claims per search results
Discovery: Discovery rule applies until age 40; after 40, 5-year window from discovery of abuse and causal connection to injury
AB 218 revival window closed; California remains active filing venue for non-time-barred claims due to larger plaintiff population and prior window activity. Search results confirm 'over 100' LDS cases filed during window
Arizona
Age 30 for child sexual abuse claims
Rule: A.R.S. § 12-514: civil action for childhood sexual abuse must commence before plaintiff turns 30
Discovery: None specified in search results; Arizona courts have rejected discovery rule for delayed realization of abuse impact
No current revival window; search results do not confirm 2025 legislative status
Idaho
Age 23 (5 years after majority) for child sexual abuse
Rule: Idaho Code § 6-1704: action must commence within 5 years after victim reaches age of majority
Discovery: Limited; Idaho courts require objective manifestation of injury within statutory period
No revival window; conservative SOL environment with significant LDS population
Nevada
Age 28 or 10 years from discovery, whichever is later
Rule: NRS § 11.215: childhood sexual abuse claims must file by age 28 or within 10 years of discovering injury was caused by abuse
Discovery: 10-year discovery period from when victim discovers or reasonably should have discovered the causal connection between abuse and injury
2021 amendment extended age limit from 26 to 28 and discovery period from 3 to 10 years; no current revival window
Washington
Age 38 or 3 years from discovery, whichever is later
Rule: RCW 4.16.340: action must commence before age 38 or within 3 years of discovering abuse and causal connection to injury, whichever period is longer
Discovery: 3-year discovery period applies after age of majority; requires discovery of both abuse and causal connection
Search results do not confirm 2024 legislation status; active LDS population in eastern Washington
| State | SOL | Rule | Discovery Rule | Notes |
|---|---|---|---|---|
| Utah | No limit for perpetrators; age 22 for non-perpetrators (4 years after majority) | Utah Code § 78B-2-308: direct claims against abusers have no SOL; third-party claims must file by age 22 or within 4 years of discovery after age 18, whichever is later | 4-year discovery period after age 18 applies only to non-perpetrator claims; narrowly construed to require total repression of memory per Colosimo v. Roman Catholic Bishop, 156 P.3d 806 (Utah 2007) | Revival window for claims time-barred as of July 1, 2016: 35 years from 18th birthday or 3 years from discovery, whichever is later; excludes claims litigated to finality or settled (unless fraud/duress) |
| California | Age 40 or 5 years from discovery, whichever is later; revival window closed | AB 218 three-year revival window (2019-2022) expired December 31, 2022; no current open window for time-barred claims per search results | Discovery rule applies until age 40; after 40, 5-year window from discovery of abuse and causal connection to injury | AB 218 revival window closed; California remains active filing venue for non-time-barred claims due to larger plaintiff population and prior window activity. Search results confirm 'over 100' LDS cases filed during window |
| Arizona | Age 30 for child sexual abuse claims | A.R.S. § 12-514: civil action for childhood sexual abuse must commence before plaintiff turns 30 | None specified in search results; Arizona courts have rejected discovery rule for delayed realization of abuse impact | No current revival window; search results do not confirm 2025 legislative status |
| Idaho | Age 23 (5 years after majority) for child sexual abuse | Idaho Code § 6-1704: action must commence within 5 years after victim reaches age of majority | Limited; Idaho courts require objective manifestation of injury within statutory period | No revival window; conservative SOL environment with significant LDS population |
| Nevada | Age 28 or 10 years from discovery, whichever is later | NRS § 11.215: childhood sexual abuse claims must file by age 28 or within 10 years of discovering injury was caused by abuse | 10-year discovery period from when victim discovers or reasonably should have discovered the causal connection between abuse and injury | 2021 amendment extended age limit from 26 to 28 and discovery period from 3 to 10 years; no current revival window |
| Washington | Age 38 or 3 years from discovery, whichever is later | RCW 4.16.340: action must commence before age 38 or within 3 years of discovering abuse and causal connection to injury, whichever period is longer | 3-year discovery period applies after age of majority; requires discovery of both abuse and causal connection | Search results do not confirm 2024 legislation status; active LDS population in eastern Washington |
Live intelligence
AI litigation brief
LDS Abuse remains active litigation category with 4 current signals in the accepted feed.
Overview
The Judicial Panel on Multidistrict Litigation denied MDL consolidation on April 3, 2025, finding case-specific factual issues precluded centralized management under 28 U.S.C. § 1407. Order signed by Judge Karen K. Caldwell. Litigation proceeds through state-level coordination in California and individual federal actions nationwide.
Key developments
Trajectory
Press coverage is active for LDS Abuse. Court-side confirmation through state civil courts and appellate rulings involving institutional abuse claims is the next escalation check.
Editorial intelligence
Editorial coverage should stay tied to source-backed developments and avoid placeholder status copy for LDS Abuse.
Generated Apr 28, 2026, 12:00 AM UTC
4 events detected
Google News (4)
2 families sue LDS Church for sexual abuse of their children at Seattle site - KIRO 7 News Seattle
Take legal action for child sexual abuse in California - Top Class Actions
This attorney has taken up hundreds of child abuse cases against the LDS Church - KUER
Appeals court overrules LDS church position, jury needs to hear details of child abuse - Arizona Capitol Times
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.
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LexGenius Ranking
48Score
Fresh items are present but not yet surging
Monitoring
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Last: Apr 28, 2026, 12:00 AM UTC
Next: 44:22
Source Monitoring
PACER
PACER
Google News
PubMed
Event feed
4
events detected
AI Brief
LDS Abuse remains active litigation category with 4 current signals in the accepted feed.
Overview
The Judicial Panel on Multidistrict Litigation denied MDL consolidation on April 3, 2025, finding case-specific factual issues precluded centralized management under 28 U.S.C. § 1407. Order signed by Judge Karen K. Caldwell. Litigation proceeds through state-level coordination in California and individual federal actions nationwide.
Key developments
KIRO 7 News Seattle news on Sep 19: 2 families sue LDS Church for sexual abuse of their children at Seattle site - KIRO 7 News Seattle.
Generated Apr 28, 2026, 12:00 AM UTC