Doe

INTRODUCTION

Does a church have a duty to protect children from sexual abuse by clergy while the children are attending religious school or participating in other church-sponsored programs? Because the answer to that question is “yes,” we reverse the judgment entered after the trial court, which answered that question “no,” granted a motion for summary judgment by the Roman Catholic Archbishop of Los Angeles, a Corporation Sole (the Archdiocese).

“A corporation sole is a perpetual entity through which a religious organization can administer and manage property dedicated to the benefit of that organization.” (Diocese of San Joaquin v. Gunner (2016) 246 Cal.App.4th 254, 260, fn. 1.) “Corporations Code section 10002 provides that ‘[a] corporation sole may be formed under this part by the bishop, chief priest, presiding elder, or other presiding officer of any religious denomination, society, or church, for the purpose of administering and managing the affairs, property, and temporalities thereof.’ Such a corporation consists only of the relevant religious officeholder and has no other corporate directors, members, or officers. In other respects, it has the same powers and…