Ariz. Rev. Stat. » Title 12
Arizona Revised Statutes

Ariz. Rev. Stat. § 12-2233 (2026)

Clergyman or priest and penitent

✓ current as of May 2026
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In a civil action a clergyman or priest shall not, without the consent of the person making a confession, be examined as to any confession made to him in his character as clergyman or priest in the course of discipline enjoined by the church to which he belongs.

Notes of Decisions
Cited in 6 cases (1 in the last 5 years), 1988–2025 · leading case: Church of Jesus Christ of Latter-Day Saints v. Superior Court, 764 P.2d 759 (Ariz. Ct. App. 1988).
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Church of Jesus Christ of Latter-Day Saints v. Superior Court, 764 P.2d 759 (Ariz. Ct. App. 1988). · cites it 19× “Ray’s privilege, it claims, is embodied in A.R.S. § 12-2233, whereas that of Stand-age, Bailey, and Taylor exists, independent of Ray’s and unwaivable by Ray, grounded in A.”
Ulibarri v. Superior Ct. Cty. of Coconino, 909 P.2d 449 (Ariz. Ct. App. 1995). · cites it 4× “]" Domb, supra. The attorney-client privilege is in the same category as other professional privileges such as the physician-patient, psychologist-patient, clergyman-penitent, and accountant-client privileges.”
Waters v. O'CONNOR, 103 P.3d 292 (Ariz. Ct. App. 2004). · cites it 4× “1988) (construing clergy-penitent privilege statute applicable in civil cases, A.R.S. § 12-2233). 3 At issue in this special action is the meaning of “clergyman,” which the statute does not define.”
In Re Grand Jury Investigation. Appeal of United States of Am., 918 F.2d 374 (3rd Cir. 1990). “Code § 12-21-166 (1989); Ariz.Rev.Stat.Ann. § 12-2233 (1989); Ark.”
Atwood v. Schriro, 489 F. Supp. 2d 982 (D. Ariz. 2007). · cites it 2× “§ 13-4062(3) and A.R.S. § 12-2233. Nor does it state whether Atwood and Bernsienne were both members of such “church” or whether Bernsienne was recognized as a “clergyman or priest,” as those terms are used in the statute.”
Rodriguez-Ramirez v. State (Ariz. Ct. App. 2025). · cites it 2× “See A.R.S. § 12-2233. ¶13 “A privilege in the law of evidence is a right which a person has in a given instance to prevent the revelation of otherwise material and relevant evidence.”
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