People v. Hodges
Superior Court of California, Appellate Department
13 Cal. Rptr. 2d 412 (1992)
A 17-year-old student, Christine, told a teacher at her Christian school that her stepfather had molested her for years, and the teacher arranged for her to speak with Hodges (defendant), the school's president and the church's pastor, who instructed her not to tell anyone and said he would handle it; Hodges and the school's principal and assistant pastor, Nobbs (defendant), arranged for the stepfather to write and deliver an apology, then pressured Christine to return home despite her objections and fear, eventually threatening to bar her from school and graduation unless she went home. Neither Hodges nor Nobbs ever reported the abuse to authorities, and both were charged and convicted under California's mandatory child-abuse reporting statute for "child care custodians"; they appealed, arguing they did not qualify as child care custodians and that applying the statute to them as religious officials was unconstitutional.
Whether religious-school administrators who also serve as church pastors qualify as mandatory child-abuse reporters under California law, and whether applying that reporting requirement to them violates their constitutional religious liberty.