Holding: A state cannot enforce a mandatory reporting law that compels Catholic priests to disclose information learned during the Sacrament of Confession, as this violates the Free Exercise Clause and clergy-penitent privilege.
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Archbishop Paul D. Etienne v. State of Washington is a Establishment Clause case decided by the U.S. District Court in 2025. The court held that a state cannot enforce a mandatory reporting law that compels Catholic priests to disclose information learned during the Sacrament of Confession, as this violates the Free Exercise Clause and clergy-penitent privilege.