Conley v. Roman Catholic Archbishop of San Francisco

In Conley v. Roman Catholic Archbishop of San Francisco (2000) 85 Cal.App.4th 1126, the court of appeal ruled that a complaint by a member of the clergy seeking relief against his superiors for defamation and infliction of emotional distress posed substantive issues that were properly before the civil courts. The plaintiff clergy person claimed his superiors' conduct amounted to imposing sanctions for making reports of suspected child abuse, sanctions which the statute forbade. (Pen. Code, 11166 .) The court held such allegations were entitled to judicial review, because the balance weighed in favor of the state's interest in protecting children, and privileged reporting must not be penalized. ( Conley, supra, 85 Cal.App.4th at p. 1132.)