Michigan Compiled Laws
Mich. Comp. Laws § 600.2156 (2026)
Minister, priest, or Christian Science practitioner; nondisclosure of confessions.
✓ current as of July 2026
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REVISED JUDICATURE ACT OF 1961
Act 236 of 1961
600.2156 Minister, priest, or Christian Science practitioner; nondisclosure of confessions.
Sec. 2156.
No minister of the gospel, or priest of any denomination whatsoever, or duly accredited Christian Science practitioner, shall be allowed to disclose any confessions made to him in his professional character, in the course of discipline enjoined by the rules or practice of such denomination.
History: 1961, Act 236, Eff. Jan. 1, 1963 ;-- Am. 1962, Act 187, Imd. Eff. May 24, 1962
Notes of Decisions
Cited in 14
cases (1 in the last 5 years), 1970–2022 · leading case: People v. Bragg, 824 N.W.2d 170 (Mich. Ct. App. 2012).
People v. Bragg, 824 N.W.2d 170 (Mich. Ct. App. 2012). “Although the prosecutor conceded that Vaprezsan was a religious minister to whom the privilege would apply under the correct circumstances, she contended that defendant’s statements were not “confessions” protected by the statute because they were *440 made in front of a third…”
People v. Watkins; People v. Pullen, 818 N.W.2d 296 (Mich. 2012). “36 MCL 600.2156. 37 For similar reasons, the majority misses the point when it concludes that my approach would result in court rules yielding to statutes that are based on some policy concerns but not others.”
Varner v. Stovall, 500 F.3d 491 (6th Cir. 2007). “See Mich. Comp. Laws § 600.2156 (requiring the communication to be made to clergy in his or her “professional character”); id.”
Smith v. Calvary Christian Church, 614 N.W.2d 590 (Mich. 2000). “§ 600.2156; MSA 27A.2156. [2] He further *592 asserted claims for breach of contract, invasion of privacy, and intentional infliction of emotional distress, and contended that the disclosure was not motivated by religious doctrine, but by the pastor's personal spite and his…”
Smith v. Calvary Christian Church, 592 N.W.2d 713 (Mich. Ct. App. 1999). “§ 600.2156; MSA 27A.2156 created a cause of action against defendant Byers based on this disclosure.”
People v. Campobello, 810 N.E.2d 307 (Ill. App. Ct. 2004). “223, § 20A (West 2002); Mich. Comp. Laws Ann. § 600.2156 (West 2002); Minn.”
Jilek v. Stockson, 796 N.W.2d 267 (Mich. Ct. App. 2010). “732; penitent-clergy communications, MCL 600.2156; spousal testimony and communications, MCL 600.”
Wirtanen v. Prudential Ins. Co. of Am., 183 N.W.2d 456 (Mich. Ct. App. 1970). “The statute governing such testimony is MCLA § 600.2156 (Stat Ann 1962 Rev § 27A.”
Dom. Linen Supply & Laundry Co. v. Stone, 314 N.W.2d 773 (Mich. Ct. App. 1981). “Wirtanen v Prudential Ins Co of America, 27 Mich App 260 ; 183 NW2d 456 (1970), MCL 600.2156; MSA 27A.2156. A similar right of confidentiality has been protected when the communication is between a patient and his doctor.”
People v. Prominski, 839 N.W.2d 32 (Mich. Ct. App. 2013). “MCL 600.2156 specifically prohibits disclosure of confessions: No minister of the gospel, or priest of any denomination whatsoever, or duly accredited Christian Science practitioner, shall be allowed to disclose any confessions made to him in his professional character, in the…”
People of Michigan v. Michael Frank Foy (Mich. Ct. App. 2020). “We granted the prosecution’s interlocutory appeal to challenge the circuit court’s decision, providing us the opportunity to analyze MCL 600.2156 and MCL 767.5a(2). Id. at 444 .”
John Doe 1 v. Orchard Lake Schs. (E.D. Mich. 2022). “5a(2); see also Mich. Comp. Laws § 600.2156 . Michigan strictly construes privileges; the privileges “‘are narrowly defined and their exceptions broadly construed.”
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