Institutional Abuse · civil actions alleging abuse and institutional failures within LDS-affiliated settings
Defendant
The Church of Jesus Christ of Latter-day Saints, a Utah corporation sole
MDL / Track
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JPML (consolidation denied)
Judge
Plaintiffs
ACTIVE
Bellwether / Trial
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Settlement Status
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Case overview
The Church of Jesus Christ of Latter-day Saints faces expanding sexual abuse litigation alleging institutional cover-ups through its clergy reporting systems, with FLOODLIT.org documenting over 266 active criminal and civil cases as of mid-2026. In Doe v. Corporation of The Presiding Bishop, 6:25-cv-00222 (D. Or.), Judge Michael J. McShane granted leave to amend but dismissed negligence claims in September 2025, finding no special relationship duty under Oregon law and no private right of action in the state's reporting statute. The Tenth Circuit heard oral arguments in May 2026 on the church's appeal of a coverage denial in the $32 million Christopher Jensen settlement, where Judge Tena Campbell ruled insurers had no duty to defend or indemnify due to late notice and occurrence disputes.
Causation Theory
Plaintiffs allege the LDS Church caused harm through a centralized institutional architecture that channeled abuse reports to church-controlled helplines and attorneys rather than law enforcement, with documented events including Kirton McConkie attorney Merrill Nelson advising a bishop not to report Paul Douglas Adams to authorities under clergy-penitent privilege, resulting in years of continued abuse until federal arrest in 2017. The church's 24/7 helpline, staffed by attorneys, is alleged to have systematized non-reporting across multiple states, including Idaho criminal case CR-1996-531 where stake president G. Farrell Young told a victim to delay police contact regarding physician LaVar Withers, who admitted to abusing at least 133 women and girls over three decades.
Litigation status
The JPML denied MDL consolidation in April 2025 (MDL No. 3150, Order Denying Transfer, Filing 83, April 3, 2025, Chair Judge Karen K. Caldwell), leaving cases dispersed across federal district courts. U.S. District Judge Michael J. McShane granted judgment on the pleadings for the LDS Church in Doe v. Corporation of the Presiding Bishop, 6:25-cv-00222 (D. Ore.), on September 8, 2026, rejecting negligence theories based on Oregon's mandatory reporting statute and finding no duty to protect a minor from abuse occurring in her home. Attorneys filed a motion for reconsideration with the Arizona Supreme Court following its August 2026 ruling that clergy are not mandatory reporters of abuse learned in confessions.
State Court Activity
Arizona Supreme Court ruled August 2026 clergy not mandatory reporters of confessional abuse, with motion for reconsideration pending; Arkansas state court filing in Pulaski County Circuit Court (J.H. v. LDS Church, filed February 2026); at least one case remanded to Oregon state court (Jane Roe EA 10, 2:24-cv-08668, C.D. Cal., remanded February 13, 2025)
Geographic exposure
California AB 218 revived SOL window creates primary US venue for adult survivors of childhood LDS abuse, including cross-state claimants. National exposure concentrated in Mountain West origin states (Utah, Arizona, Idaho) with California as dominant filing jurisdiction. No MDL established; cases proceed as individual filings in federal and state courts. Total affected population unquantified; intake teams report ongoing evaluations without public docketing of all claims.
Jane Roe CP 76 v. Doe 1, 5:24-cv-02583 (C.D. Cal. 2024): Plaintiff alleges childhood sexual abuse 1978-1980 by 'Brother Ross,' a high-ranking LDS official, at Yucaipa meetinghouse. Complaint alleges church maintained abuse-tracking membership records and operated attorney-staffed helpline that instructed bishops not to report to authorities. Filed under California AB 218 revived SOL window.
John Roe CS 88 v. Doe 1, 2:24-cv-11154 (C.D. Cal., F. Walter, J.): Nevada plaintiff removed to federal court; alleges 1991-1992 abuse by 'Perpetrator Birch' at SLO Stake. Court denied remand February 13, 2025, holding SLO Stake is Utah citizen for diversity purposes despite unincorporated California presence. Active federal litigation on jurisdictional posture.
California law firms report sustained intake volume from survivors who grew up in LDS communities in Utah, Arizona, Idaho, and other states but now reside in California. AB 218 lookback window permits revived claims against LDS Church entities with California operations. No verified state-court decisions issued as of late 2025; investigations active.
AP and PBS reporting identified Arizona cases triggering litigation alleging LDS hotline procedures shielded abusers by instructing bishops to avoid law enforcement contact. Arizona Supreme Court upheld clergy-penitent privilege protections in related case involving family complaints kept within church channels. Documented litigation events precede California filings.
AP and PBS obtained court records and interviews in West Virginia LDS abuse cases. Documented litigation events involve allegations that church policies discouraged open reporting to authorities. Precedent-setting jurisdiction for institutional-liability theories later cited by California intake teams.
Doe v. LDS Church, 167 P.3d 1193, 141 Wn. App. 407 (Wash. App. 2007): Washington Court of Appeals affirmed jury verdict for intentional infliction of emotional distress against LDS Church based on bishop's intimidating statements to abuse victim; reversed negligence verdict on mandated reporter statute interpretation. Historical precedent for IIED claims against church entities.
Kirton McConkie law firm staffs LDS Church abuse helpline from Salt Lake City headquarters at 50 East North Temple. Multiple complaints allege helpline attorneys advise local bishops against reporting to civil authorities, citing clergy-penitent privilege. Centralized policy mechanism implicated in California, Arizona, and West Virginia litigation.
Key defendants
The Church of Jesus Christ of Latter-day Saints, a Utah corporation sole
Role: Primary Religious Entity
Named Doe 1 across California filings; actively removing cases to federal court under diversity jurisdiction. Courts split on remand—E.D. Cal. (2:24-cv-03488, Judge Dale A. Drozd) and C.D. Cal. (2:24-cv-11154, Judge John F. Walter) denied remand, finding stakes non-independent; C.D. Cal. (2:24-cv-08668, Judge Stephen V. Wilson) granted remand. Aggressive forum-shopping posture suggests defense fears state-court exposure under CCP § 340.1.
Temple Corporation of the Church of Jesus Christ of Latter-day Saints
Role: Integrated Auxiliary
Named Doe 2 in complaints; Utah nonprofit corporation holding temple and property assets. Consents to removal by Church but lacks independent operational footprint. Exposure limited to property holdings; no separate defense strategy evident in dockets.
Modesto California North Stake of the Church of Jesus Christ of Latter-day Saints
Role: Ecclesiastical Subunit
Unincorporated stake in E.D. Cal. case 2:24-cv-03488; court held it is not independent for jurisdictional purposes. No separate assets, registration, or registered agent. Central to remand fights—if stakes are deemed independent, diversity jurisdiction collapses and cases return to California state court.
| Defendant | Role | Intelligence Note |
|---|---|---|
| The Church of Jesus Christ of Latter-day Saints, a Utah corporation sole | Primary Religious Entity | Named Doe 1 across California filings; actively removing cases to federal court under diversity jurisdiction. Courts split on remand—E.D. Cal. (2:24-cv-03488, Judge Dale A. Drozd) and C.D. Cal. (2:24-cv-11154, Judge John F. Walter) denied remand, finding stakes non-independent; C.D. Cal. (2:24-cv-08668, Judge Stephen V. Wilson) granted remand. Aggressive forum-shopping posture suggests defense fears state-court exposure under CCP § 340.1. |
| Temple Corporation of the Church of Jesus Christ of Latter-day Saints | Integrated Auxiliary | Named Doe 2 in complaints; Utah nonprofit corporation holding temple and property assets. Consents to removal by Church but lacks independent operational footprint. Exposure limited to property holdings; no separate defense strategy evident in dockets. |
| Modesto California North Stake of the Church of Jesus Christ of Latter-day Saints | Ecclesiastical Subunit | Unincorporated stake in E.D. Cal. case 2:24-cv-03488; court held it is not independent for jurisdictional purposes. No separate assets, registration, or registered agent. Central to remand fights—if stakes are deemed independent, diversity jurisdiction collapses and cases return to California state court. |
Timeline
Earliest Known LDS Abuse Suit Filed
Victim's mother files personal injury lawsuit in Maricopa County Superior Court against Kenneth Ray and LDS Church, alleging negligent counseling and failure to report child sexual abuse. Among first known suits against any church for sexual abuse. Case settled 1990.
Utah Supreme Court Limits Clergy Liability
Utah Supreme Court in Franco v. Church of Jesus Christ of Latter-day Saints, 2001 UT 25, 21 P.3d 198, dismisses tort claims against church, holding First Amendment bars secular duty of care on pastoral counselors in ecclesiastical settings.
Washington Appeals Court Affirms Outrage Verdict Against Church
Washington Court of Appeals in Doe v. LDS Church, 167 P.3d 1193, 141 Wn. App. 407, affirms jury verdict for intentional infliction of emotional distress against church based on bishop's intimidating statements to victim, though reverses negligence finding.
West Virginia Families Sue LDS Church for Cover-Up
Six families file suit in Berkeley County Circuit Court against church, leaders, and Michael Jensen family, alleging civil conspiracy, fraud, intentional infliction of emotional distress, and negligence over child sexual abuse cover-up spanning 2004-2012.
West Virginia High Court Revives Conspiracy Claims
Supreme Court of Appeals of West Virginia overturns 2015 circuit court dismissal, reverses exclusion of evidence, and remands for trial on conspiracy claims against church. Case proceeds after four years of litigation.
$32 Million Mid-Trial Settlement Reached
LDS Church settles West Virginia lawsuit mid-trial for $32 million after spending $27 million on defense. Total expenditure approaches $60 million. Approximately 12,000 pages of court documents sealed by 2016 West Virginia Supreme Court order.
Church Sues Insurers for Coverage Denial
LDS Church files suit in U.S. District Court for District of Utah against National Union (AIG) and ACE, seeking up to $90 million reimbursement for defense costs and settlement. Insurers refuse coverage, citing four-year delay in notice and disputing single-occurrence classification.
Bankruptcy Judge Rejects $250 Million BSA Immunity Bid
Bankruptcy Judge Laurie Selber Silverstein rejects church proposal to pay $250 million into Boy Scouts of America settlement trust in exchange for broad release from liability in 'Mixed Claim' cases involving abuse outside Scouting contexts.
Arizona Court Dismisses Adams Case on Clergy Privilege
Cochise County Superior Court Judge Timothy Dickerson dismisses lawsuit by three children of Paul Adams, ruling bishops had no duty to report under Arizona law because initial disclosure occurred during protected spiritual confession.
District Court Rules Against Church on Insurance Coverage
U.S. District Judge Tena Campbell rules for insurers, finding no duty to defend or indemnify church in West Virginia abuse case. Church appeals to Tenth Circuit; oral arguments heard May 2026.
Statute of limitations
Jurisdiction is determined by where abuse occurred, not plaintiff's current residence. LDS members often have multi-state exposure from missions, relocations, and church assignments. Utah's constitutional invalidation of revival windows (Mitchell v. Roberts, 2020 UT 34; 10th Cir. No. 21-4055, Aug. 9, 2022) and California's closed window create intake barriers for abuse in those states. Arizona's closing December 31, 2025 window is the most urgent intake priority based on source [2] references, though statutory text should be verified directly. Source [3] Colosimo establishes Utah discovery rule does not extend to institutional knowledge—screen on abuse discovery and institutional relationship only. Source [5] Doe 3 confirms California revival excludes claims litigated to finality regardless of merits determination.
Utah
No SOL for perpetrators; age 22 for non-perpetrators with 4-year discovery rule
Rule: Utah Code Ann. § 78B-2-308(3)(a): no civil SOL for claims against perpetrators for intentional or negligent child sexual abuse; § 78B-2-308(3)(b): non-perpetrator claims must be filed within 4 years after age 18, or 4 years after discovery if later
Discovery: 4-year discovery rule applies only to non-perpetrator defendants; accrues upon discovery of abuse, not institutional knowledge. Colosimo v. Catholic Diocese, 2004 UT App 356 (discovery of institutional complicity does not delay accrual)
Revival window in § 78B-2-308(7) held unconstitutional for perpetrator claims in Mitchell v. Roberts, 2020 UT 34; 10th Cir. affirmed constitutional invalidity 2022 (No. 21-4055). Non-perpetrator revival window also struck. No current revival mechanism operative in Utah.
California
Age 40 or 5 years from discovery, whichever is later; revival window closed December 31, 2022
Rule: Cal. Code Civ. Proc. § 340.1(a): action within 22 years of majority (age 40) or 5 years from discovery of psychological injury caused by assault; § 340.1(q) revived time-barred claims not litigated to finality, with 3-year window from January 1, 2020
Discovery: 5-year discovery rule from when plaintiff discovers or reasonably should discover psychological injury occurring after majority was caused by childhood sexual assault
Revival window under § 340.1(q) closed December 31, 2022. Doe 3 v. Super. Ct., 110 Cal.App.5th 571 (2025) (H051868): claims 'litigated to finality' are excluded from revival even without merits determination; claim preclusion applies. No current open revival window for new filings.
⚠Arizona
Age 30 for child sexual abuse claims; 12-year revival window opened 2019, closes December 31, 2025
Rule: Ariz. Rev. Stat. § 12-514: civil action for child sexual abuse until plaintiff reaches age 30; § 12-514(B) revived time-barred claims for 12 years from June 5, 2019
Discovery: None specified in sources; age 30 is hard deadline for claims accruing after statute's effective date
Arizona's 12-year revival window closes December 31, 2025—approximately 3 months from current date. Source [2] references Arizona appellate rulings permitting claims where bishops failed to report, but does not specify statutory text. Verify Ariz. Rev. Stat. § 12-514(B) directly for precise closure date.
New York
Age 55; revival window closed August 14, 2021
Rule: N.Y. C.P.L.R. § 213-c: child sexual abuse actions until plaintiff reaches age 55; Child Victims Act revived time-barred claims with 2-year window from August 14, 2019
Discovery: None; age 55 is hard deadline for post-CVA claims
CVA revival window closed August 14, 2021. Adult Survivors Act one-year window closed November 24, 2024. No current open revival window. LDS abuse claims must meet age 55 deadline if abuse discovered/reported after CVA effective date. Not specifically mentioned in provided sources; verify independently.
Idaho
Age 23 for child sexual abuse; no current revival window
Rule: Idaho Code § 6-1704: action for injury from childhood sexual abuse within 5 years of reaching age 18 (age 23)
Discovery: None specified; hard age 23 deadline
Idaho has not enacted a revival window for LDS abuse claims. Source [2] notes Idaho as state with LDS population affected by location-based rules, but no statutory citation provided in sources. Verify Idaho Code § 6-1704 independently.
Colorado
Age 24 for child sexual abuse; revival window closed January 1, 2025
Rule: Colo. Rev. Stat. § 13-80-103.7: action for child sexual abuse until age 24; revived time-barred claims with 3-year window from January 1, 2022
Discovery: None specified in provided sources
Colorado's Child Sexual Abuse Accountability Act revival window closed January 1, 2025. No current open window. Discovery rule claim in draft not supported by provided sources; removed pending verification. Not mentioned in provided sources; verify Colo. Rev. Stat. § 13-80-103.7 independently.
| State | SOL | Rule | Discovery Rule | Notes |
|---|---|---|---|---|
| Utah | No SOL for perpetrators; age 22 for non-perpetrators with 4-year discovery rule | Utah Code Ann. § 78B-2-308(3)(a): no civil SOL for claims against perpetrators for intentional or negligent child sexual abuse; § 78B-2-308(3)(b): non-perpetrator claims must be filed within 4 years after age 18, or 4 years after discovery if later | 4-year discovery rule applies only to non-perpetrator defendants; accrues upon discovery of abuse, not institutional knowledge. Colosimo v. Catholic Diocese, 2004 UT App 356 (discovery of institutional complicity does not delay accrual) | Revival window in § 78B-2-308(7) held unconstitutional for perpetrator claims in Mitchell v. Roberts, 2020 UT 34; 10th Cir. affirmed constitutional invalidity 2022 (No. 21-4055). Non-perpetrator revival window also struck. No current revival mechanism operative in Utah. |
| California | Age 40 or 5 years from discovery, whichever is later; revival window closed December 31, 2022 | Cal. Code Civ. Proc. § 340.1(a): action within 22 years of majority (age 40) or 5 years from discovery of psychological injury caused by assault; § 340.1(q) revived time-barred claims not litigated to finality, with 3-year window from January 1, 2020 | 5-year discovery rule from when plaintiff discovers or reasonably should discover psychological injury occurring after majority was caused by childhood sexual assault | Revival window under § 340.1(q) closed December 31, 2022. Doe 3 v. Super. Ct., 110 Cal.App.5th 571 (2025) (H051868): claims 'litigated to finality' are excluded from revival even without merits determination; claim preclusion applies. No current open revival window for new filings. |
| ⚠Arizona | Age 30 for child sexual abuse claims; 12-year revival window opened 2019, closes December 31, 2025 | Ariz. Rev. Stat. § 12-514: civil action for child sexual abuse until plaintiff reaches age 30; § 12-514(B) revived time-barred claims for 12 years from June 5, 2019 | None specified in sources; age 30 is hard deadline for claims accruing after statute's effective date | Arizona's 12-year revival window closes December 31, 2025—approximately 3 months from current date. Source [2] references Arizona appellate rulings permitting claims where bishops failed to report, but does not specify statutory text. Verify Ariz. Rev. Stat. § 12-514(B) directly for precise closure date. |
| New York | Age 55; revival window closed August 14, 2021 | N.Y. C.P.L.R. § 213-c: child sexual abuse actions until plaintiff reaches age 55; Child Victims Act revived time-barred claims with 2-year window from August 14, 2019 | None; age 55 is hard deadline for post-CVA claims | CVA revival window closed August 14, 2021. Adult Survivors Act one-year window closed November 24, 2024. No current open revival window. LDS abuse claims must meet age 55 deadline if abuse discovered/reported after CVA effective date. Not specifically mentioned in provided sources; verify independently. |
| Idaho | Age 23 for child sexual abuse; no current revival window | Idaho Code § 6-1704: action for injury from childhood sexual abuse within 5 years of reaching age 18 (age 23) | None specified; hard age 23 deadline | Idaho has not enacted a revival window for LDS abuse claims. Source [2] notes Idaho as state with LDS population affected by location-based rules, but no statutory citation provided in sources. Verify Idaho Code § 6-1704 independently. |
| Colorado | Age 24 for child sexual abuse; revival window closed January 1, 2025 | Colo. Rev. Stat. § 13-80-103.7: action for child sexual abuse until age 24; revived time-barred claims with 3-year window from January 1, 2022 | None specified in provided sources | Colorado's Child Sexual Abuse Accountability Act revival window closed January 1, 2025. No current open window. Discovery rule claim in draft not supported by provided sources; removed pending verification. Not mentioned in provided sources; verify Colo. Rev. Stat. § 13-80-103.7 independently. |
Live intelligence
AI litigation brief
LDS Abuse remains active litigation category with 27 current signals in the accepted feed.
Overview
The JPML denied MDL consolidation in April 2025 (MDL No. 3150, Order Denying Transfer, Filing 83, April 3, 2025, Chair Judge Karen K. Caldwell), leaving cases dispersed across federal district courts. U.S. District Judge Michael J. McShane granted judgment on the pleadings for the LDS Church in Doe v. Corporation of the Presiding Bishop, 6:25-cv-00222 (D. Ore.), on September 8, 2026, rejecting negligence theories based on Oregon's mandatory reporting statute and finding no duty to protect a minor from abuse occurring in her home. Attorneys filed a motion for reconsideration with the Arizona Supreme Court following its August 2026 ruling that clergy are not mandatory reporters of abuse learned in confessions.
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 Sep 30, 2026, 10:00 AM UTC
27 events detected
Google News (27)
Attorneys ask Arizona Supreme Court to rethink LDS abuse ruling - Eastern Arizona Courier
LDS Church leaders not bound to report sexual abuse confessions, Arizona Supreme Court rules - The Salt Lake Tribune
Church leaders not bound to report sexual abuse confessions, Arizona Supreme Court rules - Religion News Service
Arizona ruling: Religions don't have to report child sex abuse to authorities - tucson.com
Arizona clergy who learn of child abuse in confessions aren’t required to report it, court rules - The Guardian
What the Bisbee LDS Ruling Means for Arizona - Herald/Review Media
What the Bisbee LDS Ruling Means for Arizona - myheraldreview.com
Religious leaders not required to report child abuse, Arizona Supreme Court rules - FOX 13 News Utah
Arizona Supreme Court rules clergy abuse reporting optional - wng.org
LDS church didn't have to report child sex abuse, Arizona court rules - azcentral.com and The Arizona Republic
The Church, Sexual Abuse, and Insurance - By Common Consent
AZ Supreme Court dismisses LDS Church abuse case in Cochise County - KVOA
High court says churches, not judges, define a ‘confession’ when it comes to reporting child abuse - Arizona Mirror
Arizona Supreme Court sides with LDS Church in 'duty-to-report' abuse case - 12News
Federal appeals court sides with LDS Church in lawsuit over sex abuse settlements - The Salt Lake Tribune
Appeals court revives LDS Church's coverage fight against two insurers - Insurance Business
AZ Supreme Court Rules In Cochise County Case That Churches Don't Have to Report Child Abuse - myheraldreview.com
AZ Supreme Court Rules In Cochise County Case That Churches Don't Have to Report Child Abuse - Herald/Review Media
Arizona Supreme Court sides with LDS Church in 'duty-to-report' abuse case - 12news.com
Federal court overturns decision requiring LDS Church to pay settlement in sexual abuse lawsuit - ABC4 Utah
LDS Church May Pursue Abuse Suit Coverage, 10th Circ. Says - Law360
10th Circuit revives Mormon Church's fight with insurers over sex abuse settlements - Courthouse News
Mormon Church Gets Suit Over Abuse Liability Coverage Reinstated - Bloomberg Law News
Brother of LDS apostle pleads guilty to sexually abusing, enticing minors in Ohio and Utah - ABC4 Utah
Mormon church files motion to dismiss sexual abuse lawsuit - Texarkana Gazette
Mormon church files motion to dismiss sexual abuse lawsuit - The Arkansas Democrat-Gazette
Mormon church files motion to dismiss sexual abuse lawsuit - Northwest Arkansas Democrat-Gazette
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AI Brief
LDS Abuse remains active litigation category with 27 current signals in the accepted feed.
Overview
The JPML denied MDL consolidation in April 2025 (MDL No. 3150, Order Denying Transfer, Filing 83, April 3, 2025, Chair Judge Karen K. Caldwell), leaving cases dispersed across federal district courts. U.S. District Judge Michael J. McShane granted judgment on the pleadings for the LDS Church in Doe v. Corporation of the Presiding Bishop, 6:25-cv-00222 (D. Ore.), on September 8, 2026, rejecting negligence theories based on Oregon's mandatory reporting statute and finding no duty to protect a minor from abuse occurring in her home. Attorneys filed a motion for reconsideration with the Arizona Supreme Court following its August 2026 ruling that clergy are not mandatory reporters of abuse learned in confessions.
Key developments
Eastern Arizona Courier news on Aug 14: Attorneys ask Arizona Supreme Court to rethink LDS abuse ruling - Eastern Arizona Courier.
Generated Sep 30, 2026, 10:00 AM UTC