N.K., Appellant, v. Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-Day Saints et al., Respondents., 175 Wn. App. 517

Summary

The adult alleged that the defendants had a duty to protect him from the criminal acts of the volunteer scout leader. He claimed that the defendants failed to check into the volunteer's background, allowed the volunteer to supervise children in isolated settings without another adult present, and failed to train scoutmasters or warn scouts and their families about the danger of sexual abuse in scouting. The appellate court held that the church had a protective relationship with the adult when he was a child that gave rise to a duty to protect him from foreseeable harms, including the risk of sex abuse by scout leaders. The duty did not depend on prior knowledge by the church that the volunteer was a molester. The other defendants did not have a duty because their relationship to the scouts in the troop was not custodial. The appellate court also held that the trial court erred by limiting the church's disclosure of its knowledge and handling of previous allegations of child abuse ...