Federal Judge Rules Church Not Legally Obligated to Protect Abuse Survivor
A federal magistrate has dismissed claims against The Church of Jesus Christ of Latter-day Saints and two affiliated entities in a negligence lawsuit brought by a sexual abuse survivor, determining that the faith organization owed her no legal duty to safeguard her from harm inflicted by her adoptive father during periods outside church oversight.
U.S. District Judge Michael J. McShane issued the ruling in September, resolving key arguments centered on the church’s responsibility under Oregon negligence principles. Earlier reporting had highlighted the “no legal duty” defense now upheld by the court.
The plaintiff, using the pseudonym Julie Doe, alleged ongoing abuse by Craig Ford beginning in 2015 while she lived with him and his wife, Jennifer Ford, as part of an LDS ward in Ridgefield, Washington. After the Fords relocated her to Albany, Oregon, the abuse persisted, though church leaders remained unaware—or inactive—in their response.
Judge McShane acknowledged that the church’s protocols appeared inadequate in light of the circumstances, describing its policies as “ring[ing] disappointingly hollow.” Still, he found Doe’s factual assertions insufficient to impose liability, particularly since the alleged harm occurred outside church-sponsored settings and without direct involvement from ecclesiastical leadership.
The court’s order permitted Doe to submit an updated complaint and incorporated its broader claims into the final judgment. The decision came via judgment on the pleadings, meaning the judge assessed the legal sufficiency of the allegations without requiring a full trial.
Records show Craig Ford was first convicted in Oregon in 2021 on charges of incest and rape related to Doe, then faced a second conviction in Washington the following year for comparable offenses. The civil suit targeted the church’s conduct before those criminal outcomes.
According to the pleadings, Doe entered foster care with the Fords in 2013 and was formally adopted two years later. The family joined an LDS congregation in Ridgefield in 2014, after which Craig Ford initiated sexual abuse in December 2015, when Doe was fifteen.
Jennifer Ford reportedly raised concerns with Stake President Wade Pickett in April 2016, sharing a letter Craig had written to Doe as evidence of their relationship. Pickett allegedly did not alert civil authorities, encouraged Jennifer to refrain from doing so, and offered limited support to Doe—actions the plaintiff claimed increased risk by enabling Craig to maintain control.
That same month, the Fords moved to Albany, Oregon, where the abuse continued. Doe maintained she remained active in local church activities despite the ongoing mistreatment.
Doe further alleged that regional church leadership informed Salt Lake City officials of the situation by December 2016, with internal notes characterizing the abuse as involving “consensual relations” and flagging Craig’s membership record for “Child Abuse or Incest.”
In February 2017, local Bishop Daniel White reportedly learned of Doe’s living arrangement and history of abuse yet took no formal steps. Church participation continued uninterrupted, with Doe attending services and programs as before.
Central to the litigation was whether the church’s conduct—particularly its reticence to escalate concerns externally and its framing of the abuse—created a special relationship or heightened obligation toward Doe.
Doe contended the church’s involvement, including discouragement of reporting and downplaying of severity, contributed to Craig Ford’s ability to isolate her in Oregon, thereby increasing her vulnerability.
A federal judge determined that the plaintiffs’ claims were best understood as complaints about inaction rather than affirmative acts that generated the danger. In a written ruling, Judge McShane stated that while the defendants’ failure to act was troubling, they did not originate the risk that injured the plaintiff. Consequently, under standard negligence principles, the defendants owed no duty to shield the plaintiff from the abuse inflicted by her father within their home.
The court also dismissed the contention that the plaintiff’s status as a church member created a special relationship mandating protection extending beyond the scope of church supervision. Judge McShane noted that while such a relationship might form during organized religious activities, the plaintiff did not claim the abuse took place under the direct oversight of church leaders. The judge concluded that any special duty arising from supervision ceased once the plaintiff returned to her father’s care.
The ruling further held that Oregon’s mandatory reporting statute for child abuse did not provide a foundation for the negligence claim. Although the plaintiff alleged that church representatives in Albany were aware of the abuse but failed to file a report, the judge explained that the statute does not inherently grant individuals the right to sue. The plaintiff also failed to cite legal precedent establishing that a common-law duty arises solely from these reporting laws.
This determination addressed the civil liability of the defendants. The order did not, however, resolve whether the alleged failure to report constituted a criminal offense.
The plaintiff also contended that the church had voluntarily assumed a duty to protect her through its internal abuse policies. These policies, as detailed in the court documents, urged leaders to take disclosures seriously, notify civil authorities, safeguard survivors from further injury, and offer support. Judge McShane found that broad policy statements were insufficient to prove that the defendants undertook a specific duty to protect this particular plaintiff.
Although the judge criticized the policies as lacking substance, he noted that the complaint did not describe concrete actions taken to rescue the plaintiff that would support a theory of voluntary assumption of duty. The judge also reasoned that holding organizations liable for abuse occurring outside their supervision, based solely on the existence of prevention policies, might discourage groups from adopting such measures.
The court rejected the final argument that church leaders should have warned the plaintiff about the long-term psychological and emotional consequences of the ongoing abuse. The plaintiff had claimed she misinterpreted her father’s sexual contact as affection and that an intervention would have helped her exit the situation sooner. Judge McShane countered that the plaintiff was already aware of the harm caused by her father’s continued abuse by the time church leaders became involved. He concluded that no reasonable factfinder could determine that a warning would have averted the injury.
The church had previously argued that its alleged discouragement of reporting was shielded by the First Amendment, a position the plaintiff contested, according to earlier reporting. Judge McShane issued judgment on the negligence claims without resolving this constitutional question.