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New Mexico

N.M. Stat. Ann. § 32A-4-3New Mexico mandatory-reporting statute

Clergy named as mandatory reporter?
Yes
Confessional exemption?
Yes
Statute
N.M. Stat. Ann. § 32A-4-3
Clergy named
Expressly
Pending

New Mexico law names clergy as mandated reporters of child abuse and neglect, but only when the information is not privileged as a matter of law. The statute itself does not define what counts as privileged. That definition lives in Rule 11-506 NMRA, the clergy-penitent privilege adopted by the New Mexico Supreme Court as part of the Rules of Evidence. The result is a two-move dodge: the legislature names clergy in § 32A-4-3(A), then defers the operative limit on the duty to a court rule the legislature cannot unilaterally amend. The New Mexico Constitution reserves the rules of evidence to the Supreme Court, so the legislature cannot rewrite that limit on its own (Ammerman v. Hubbard Broadcasting, 1976); the Court read the reporting duty itself as universal in State v. Strauch (2015), and an unpublished Court of Appeals decision, State v. Pritchett (2021), held the reporting statute does not by itself override the clergy-penitent privilege. A 2025 statutory amendment that touched neighboring subsections left the clergy language and the privilege qualifier untouched. Reform here means moving two pieces, a statute and a court rule, at once.

Section 01What needs to change

What needs to change in New Mexico.

  • Clergy expressly named at § 32A-4-3(A), qualified by privilege

    Subsection (A) enumerates 'a member of the clergy who has information that is not privileged as a matter of law' among mandated reporters, alongside physicians, residents, interns, law enforcement officers, judges, registered and visiting nurses, school employees, and social workers acting in an official capacity. Reports must go immediately to local law enforcement, the department (now the Health Care Authority for plan-of-safe-care notification), or a tribal agency for any Indian child residing in Indian country. Failure to report is a misdemeanor under § 32A-4-3(F).

    View source ↗
  • Clergy-penitent privilege lives in Rule 11-506 NMRA, not in statute

    New Mexico's clergy-penitent privilege is codified at **Rule 11-506 NMRA**, part of the judicial-branch Rules of Evidence. It lets a person refuse to disclose, and prevent a clergy member from disclosing, a confidential communication made for the purpose of seeking spiritual advice. Because Rule 11-506 sits in the judicial-branch Rules of Evidence, the privilege qualifier in § 32A-4-3(A) points to a court rule rather than to statutory text.

    View source ↗
  • 2025 amendment left the clergy and privilege language untouched

    Laws 2025, ch. 156, § 8 (effective June 20, 2025) amended § 32A-4-3 to rename plan-of-care to plan-of-safe-care, shift federal CARA compliance from CYFD to the Health Care Authority, and extend Subsection H coverage to clinics providing prenatal or perinatal care. The Subsection A reporter list, the clergy enumeration, and the 'not privileged as a matter of law' qualifier were not touched. The expressly-named / privilege-preserved framework carried straight through the most recent revision.

    View source ↗
Section 02What's needed

What it takes to close the gap.

Section 03How you can help

Concrete ways to support reform in New Mexico.

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Section 04Timeline

How New Mexico got here.

  • 2003
    Clergy added to the reporter list

    Laws 2003, ch. 189, § 1 amended § 32A-4-3 to add 'a member of the clergy' to the enumerated mandated reporters and to attach the qualifier 'who has information that is not privileged as a matter of law.' The amendment shaped the structural split that still defines New Mexico's posture today.

    View source ↗
  • 2015
    Strauch: a mandated reporter's statements were not privileged

    The New Mexico Supreme Court reads § 32A-4-3(A) broadly as a universal reporting duty and holds that a licensed social worker's confidential statements were not privileged, because Rule 11-504(D)(4) NMRA withdraws that privilege for matters a reporter is required by law to report. The case construes the social-worker privilege, not the clergy-penitent privilege in Rule 11-506, which has no equivalent reporting exception.

    View source ↗
  • 2021
    Pritchett applies the framework to a pastor's testimony

    The Court of Appeals holds that the reporting statute did not make a pastor's privileged communications admissible, reinforcing that § 32A-4-3 does not override the Rule 11-506 NMRA clergy-penitent privilege.

    View source ↗
  • 2025-06
    Statutory revision leaves the carveout in place

    Laws 2025, ch. 156, § 8 takes effect June 20, 2025, retitling plan-of-care to plan-of-safe-care and shifting responsibilities from CYFD to the Health Care Authority. The clergy enumeration and the 'not privileged as a matter of law' qualifier in Subsection A are not amended.

    View source ↗
Section 05Key cases

Litigation shaping the law.

  • State v. Strauch

    2015-NMSC-009, 345 P.3d 3172015

    The New Mexico Supreme Court read § 32A-4-3(A) broadly to impose a reporting duty on 'every person,' rejecting the Court of Appeals' narrower reading limited to enumerated professionals. Applying the exception in Rule 11-504(D)(4) NMRA, which withdraws the psychotherapist and social-worker privilege for any matter a reporter is required by law to report, the Court held that a licensed social worker was a mandated reporter and that the defendant's confidential statements to that social worker were not privileged. Strauch construes the social-worker privilege in Rule 11-504; it did not decide the clergy-penitent privilege in Rule 11-506, which contains no equivalent reporting exception.

    View source ↗
  • State v. Pritchett

    2021 WL 3674571 (N.M. App. 2021)2021

    An unpublished New Mexico Court of Appeals decision addressing a pastor's testimony. The court held that § 32A-4-3 did not strip the privilege from confidential pastor-penitent communications or make them admissible. Pritchett indicates the mandatory-reporter statute does not, on its own, override the Rule 11-506 NMRA clergy-penitent privilege.

    View source ↗
Section 06Background

Public-record sources UCO is tracking.

Always verify against the underlying statute or filing before quoting.

  • New Mexico Compilation Commission / NMOneSource· current through 2025 session
    N.M. Stat. Ann. § 32A-4-3 — Duty to report child abuse and child neglect (NMOneSource, official)

    Official state legal-research source published by the New Mexico Compilation Commission. Subsection (A) enumerates a member of the clergy alongside the other mandated reporters and attaches the 'who has information that is not privileged as a matter of law' qualifier that anchors the privilege-preserved posture.

    View source ↗
  • Justia US Law· 2025
    New Mexico Statutes Section 32A-4-3 (2025) — Justia mirror

    Mirror of the current statute reflecting Laws 2025, ch. 156, § 8 (effective June 20, 2025). Justia's history line confirms that the clergy enumeration was inserted by the 2003 amendment and that the 2025 revision did not touch the Subsection A reporter list or the privilege qualifier.

    View source ↗
  • Leagle (New Mexico Supreme Court opinion text)· March 9, 2015
    State v. Strauch, 2015-NMSC-009, 345 P.3d 317

    Full text of the New Mexico Supreme Court opinion reading § 32A-4-3(A) as imposing a universal reporting duty and holding, under the Rule 11-504(D)(4) NMRA exception, that a mandated reporter's confidential social-worker communications were not privileged.

    View source ↗
  • Victim Rights Law Center· 2020
    Clergy Privacy FAQs — New Mexico

    Practitioner FAQ quoting Rule 11-506(B) NMRA on the clergy-penitent privilege and tying it to the § 32A-4-3 reporting carve-out. Useful primary anchor for the Rule 11-506 NMRA text and the statute-to-rule cross-reference.

    View source ↗
  • Child Welfare Information Gateway, U.S. HHS Children's Bureau· May 2023
    Clergy as Mandatory Reporters of Child Abuse and Neglect — New Mexico

    Federal state-statute summary citing § 32A-4-3 and categorizing New Mexico as a state that both expressly enumerates clergy as mandated reporters and preserves the clergy-penitent privilege. Independent cross-validation for the expressly-named / privilege-preserved classification.

    View source ↗
  • Reporters Committee for Freedom of the Press, New Mexico Privilege Compendium· 1976
    Ammerman v. Hubbard Broadcasting, Inc., 89 N.M. 307, 551 P.2d 1354 (N.M. 1976)

    New Mexico Supreme Court held that under the state Constitution the Legislature lacks power to prescribe rules of evidence and procedure, which are vested exclusively in the court. Substantiates the constitutional reservation of rule-making authority the page relies on to explain why closing the gap requires both a statute and a Supreme Court rule change.

    View source ↗
Last reviewed July 21, 2026 · by Unheard Child Org research teamHow we track this

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