Kansas City Clergy and Church Sexual Abuse Lawyer

What investigations found about clergy abuse in Kansas and Missouri

State investigations have documented historical allegations involving Catholic clergy in both Kansas and Missouri. These reports provide broader context, although the findings do not establish civil liability in any particular survivor’s case.

The Kansas Bureau of Investigation began a statewide investigation in 2018 involving the four Catholic dioceses in Kansas. Its January 2023 summary reported that investigators reviewed allegations involving 188 clergy members and completed 30 probable-cause affidavits identifying 14 clergy members for possible prosecution. Many allegations were too old to prosecute under the criminal statutes then applicable or involved clergy who had died.

The investigation included the Archdiocese of Kansas City in Kansas. The archdiocese separately publishes a list of clergy with substantiated allegations of sexual abuse of minors.

Missouri’s attorney general released a statewide Catholic clergy abuse investigation in September 2019. The review examined records concerning more than 2,000 priests along with hundreds of deacons, seminarians and religious women. The report identified 163 clergy members accused of sexual abuse or misconduct involving minors and referred 12 former clergy members for possible criminal prosecution.

The Diocese of Kansas City-St. Joseph also maintains a list of clergy with substantiated allegations. The diocese has said its 2019 review included files dating to the creation of the diocese in 1956 and was conducted by an outside team that included former FBI agents.

A published church list or government investigation may provide leads, but it is not the only way to establish a civil claim. Survivors can have viable cases even when a perpetrator does not appear on a public list.

Can you sue a church for sexual abuse?

Potentially, yes. A survivor may have a claim against the person who committed the abuse and, depending on the facts and applicable state law, against a church, diocese, congregation, religious order or other organization.

Institutional claims usually focus on the organization’s own conduct. Questions may include:

• Whether leaders had received earlier complaints or reports
• Whether the organization knew an individual posed a danger
• Whether it continued giving that person access to children or vulnerable adults
• Whether reasonable supervision was provided
• Whether records or assignment histories show previous concerns
• Whether leadership concealed or failed to act on known misconduct

Liability is not automatic simply because the person who committed the abuse was a priest, pastor, employee or volunteer. The evidence must support a recognized legal claim against the particular institution.

Missouri presents an especially important complication because state courts restrict some negligence claims against religious organizations under the First Amendment.

Missouri’s church negligence rule: Gibson v. Brewer

Missouri clergy abuse cases require different legal analysis from ordinary negligent hiring or supervision cases.

In Gibson v. Brewer, the Missouri Supreme Court held that claims alleging negligent hiring, ordination, retention and supervision of clergy could require civil courts to evaluate religious doctrine, church governance or standards for selecting and supervising ministers. The court held that those negligence theories were barred by First Amendment principles.

That does not mean a Missouri religious organization is immune from every civil sexual abuse claim.

Gibson recognized a claim for intentional failure to supervise clergy under defined circumstances. Among other requirements, the evidence must support that a supervisory relationship existed, the supervisor knew harm was certain or substantially certain to result, deliberately disregarded that risk and the failure to act caused the survivor’s injury. Missouri courts continue to apply Gibson. In 2021, the Missouri Supreme Court reaffirmed its treatment of barred negligence claims and intentional-failure-to-supervise claims in John Doe 122 v. Marianist Province.

This distinction can make prior complaints, internal communications and evidence showing actual knowledge particularly important in a Missouri church abuse case.

Missouri vs. Kansas clergy abuse claims

Because the Kansas City metro spans two states, survivors should not assume the same rules apply to abuse that occurred in Missouri and Kansas. Several important differences can affect a clergy sexual abuse claim.

Childhood sexual abuse claims against the perpetrator

Missouri: Current § 537.046 generally provides until age 31 or three years after the survivor discovers or reasonably should have discovered the causal relationship between the abuse and the resulting injury or illness, whichever is later.

Kansas: Current K.S.A. 60-523 generally provides until age 31 or three years after a qualifying criminal conviction related to the abuse, whichever is later.

Claims against a church or religious organization

Missouri: Gibson v. Brewer limits certain negligent hiring, retention and supervision claims involving clergy. An intentional-failure-to-supervise claim may be available when its specific requirements are satisfied.

Kansas: Kansas does not have the same controlling rule as Gibson. Negligence theories may be available against religious organizations depending on the facts, although First Amendment defenses can still apply in particular cases.

Clergy reporting requirements

Missouri: Missouri law specifically addresses reporting responsibilities for ministers, subject to a limited exception for certain confidential clergy communications.

Kansas: Clergy are not separately listed as mandatory reporters in current K.S.A. 38-2223. A clergy member may nevertheless have a reporting duty if they also serve in another profession covered by the statute.

Nondisclosure agreements involving childhood sexual abuse

Missouri: For actions arising on or after August 28, 2025, current § 537.046 makes certain nondisclosure agreements involving covered childhood sexual abuse allegations or claims void and unenforceable.

Kansas: K.S.A. 60-523 does not contain the same statutory nondisclosure-agreement provision.

These differences are one reason the location of the abuse, identity of each defendant and applicable state law should be determined before evaluating a potential claim.