Legal Opinion

Doe v. Corporation of the President of the Church of Jesus Christ of Latter-Day Saints

Court of Appeals of Washington

Decided June 1, 2004No. 52452-6-IPublishedCited by 7 opinions

1Opinion of the CourtSchindler, J.

The trial court ordered the Corporation of the President of the Church of Jesus Christ of Latter-Day Saints (LDS Church)1 to disclose the report of church disciplinary action (RCDA) for John Roe, a church member, who abused his stepdaughters, Jane and Rebecca Doe.2 In analyzing whether the clergy-penitent privilege protected Roe’s RCDA from disclosure, the trial court found that the RCDA was a confession “made ... in the course of discipline enjoined by the church,” and that it was made in confidence. However, the court concluded the clergy-penitent privilege did not apply because the LDS…

2Cases cited19 opinions

  1. Kedroff v. Saint Nicholas Cathedral of the Russian Orthodox Church in North AmericaSupreme Court of the United States · 1952
  2. Davis v. Department of LicensingWashington Supreme Court · 1999
  3. Equal Employment Opportunity Commission and Elizabeth McDonough v. The Catholic University of AmericaCourt of Appeals for the D.C. Circuit · 1996
  4. Bryce v. Episcopal Church in the Diocese of ColoradoCourt of Appeals for the Tenth Circuit · 2002
  5. State v. HallWashington Supreme Court · 1981

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3Cited by7 opinions

  1. Doe v. Corporation of the President of the Church of Jesus Christ of Latter-Day SaintsCourt of Appeals of Washington · 2007
  2. N.K. v. Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-Day SaintsCourt of Appeals of Washington · 2013
  3. Doehne v. EmPres Healthcare Management, LLCCourt of Appeals of Washington · 2015
  4. Norton v. U.S. Bank National Ass'nCourt of Appeals of Washington · 2014
  5. Micahn T. Carter v. Mary E. JonesCourt of Appeals of Washington · 2025

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