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.
By ReligiousLiberty.TV • February 26, 2026 • U.S. Const. amend. I
Cite This Case
Archbishop Paul D. Etienne v. State of Washington (D. 2025).
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Archbishop Paul D. Etienne v. State of Washington (U.S. District Court, 2025). https://religiousliberty.tv/case-library/washington-clergy-confession/
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Archbishop Paul D. Etienne v. State of Washington [U.S. District Court, 2025] — 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. Source: ReligiousLiberty.TV (https://religiousliberty.tv/case-library/washington-clergy-confession/, accessed October 23, 2026).
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⚠ No official reporter citation found for this case. Citation quality will improve once a reporter citation (e.g. 573 U.S. 682) is added to the case record.
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.