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Virginia

Va. Code § 63.2-1509(A)(19)Virginia child-abuse reporting statute (clergy named, privilege carveout)

Clergy named as mandatory reporter?
Yes
Confessional exemption?
Yes
Statute
Va. Code § 63.2-1509(A)(19)
Clergy named
Expressly
Pending

Virginia added clergy to its mandated-reporter list in 2019. Section 63.2-1509(A)(19) names ministers, priests, rabbis, imams, and duly accredited practitioners of any religious organization. The duty sounds firm on the page. The same subsection then writes two exemptions back in. Clause (i) excuses information the relevant religious organization's doctrine requires to be kept confidential. Clause (ii) preserves communications that would be subject to Va. Code § 8.01-400 (the civil clergy privilege) or § 19.2-271.3 (the criminal counterpart) if offered as evidence in court. The practical effect is a wide carveout. The doctrinal clause turns on what a denomination requires of its clergy, with no procedural burden on the clergyperson to substantiate the claim. The privilege clause imports the full reach of Virginia's evidentiary statutes, which extend beyond the confessional to communications made while a person was 'seeking spiritual counsel and advice.' Any denomination that treats pastoral counseling as confidential can leave its clergy outside the duty. Virginia case law adds a second layer. Under Nestle v. Commonwealth (1996), the clergy-penitent privilege belongs to the clergyperson, not the communicant. A survivor who wants the disclosure to come out cannot force it; the clergy member alone decides whether to invoke the carveout. The federal companion authority, Seidman v. Fishburne-Hudgins (4th Cir. 1984), points the same way. The legislative record confirms the design. The carveout was written to protect the confessional, and the Virginia Catholic Conference, which represents the state's two Catholic dioceses, supported both bills. The bills cleared both chambers unanimously and took effect July 1, 2019. A duty that names clergy and then writes its own way out is the pattern UCO works to close, statehouse by statehouse, until the exception no longer decides whether a child is protected.

Section 01What needs to change

What needs to change in Virginia.

  • Clergy expressly enumerated at § 63.2-1509(A)(19) since 2019

    Virginia's child-abuse reporting statute lists clergy as the nineteenth category of mandated reporter. Section 63.2-1509(A)(19) names 'any minister, priest, rabbi, imam, or duly accredited practitioner of any religious organization or denomination usually referred to as a church.' Clergy were added by 2019 amendments effective July 1, 2019; the reporting channel is the statewide Child Abuse and Neglect Hotline operated by the Virginia Department of Social Services.

    View source ↗
  • The carveout lives in the same subsection: doctrinal confidentiality + civil and criminal privilege cross-refs

    Section 63.2-1509(A)(19) qualifies the clergy reporting duty in two ways within the same subsection. Clause (i) exempts information that is required by the doctrine of the religious organization or denomination to be kept in a confidential manner. Clause (ii) exempts information that would be subject to Va. Code § 8.01-400 or § 19.2-271.3 if offered as evidence in court. The doctrinal clause turns on the denomination's own discipline, not on whether the disclosure resembled a sacramental confession, and the statute imposes no procedural burden on the clergyperson to substantiate the doctrinal claim. The privilege clause imports the full breadth of Virginia's evidentiary statutes, which protect confidential communications made to a minister where the communicant was 'seeking spiritual counsel and advice.'

    View source ↗
  • Civil and criminal clergy privileges preserved by reference (§ 8.01-400 and § 19.2-271.3)

    Virginia's civil clergy privilege at § 8.01-400 bars compelling qualifying clergy to testify, relinquish notes or records, or disclose confidential information communicated for spiritual counsel and advice. The criminal counterpart at § 19.2-271.3 bars compelling clergy testimony in criminal actions about confidential communications from an accused person seeking spiritual counsel. Because § 63.2-1509(A)(19)(ii) incorporates both statutes by reference, the privileges sit inside the reporting regime, not outside it.

    View source ↗
  • Privilege is held by the clergyperson, not the penitent or accused (Nestle v. Commonwealth)

    Under Virginia law, the clergy-penitent privilege belongs to the clergyperson, not the communicant. The Virginia Court of Appeals held in Nestle v. Commonwealth, 22 Va. App. 336, 470 S.E.2d 133 (1996), that it was error to allow a criminal defendant to invoke the privilege to refuse to divulge a confessional statement; the clergy member is the privilege-holder. The Fourth Circuit reached a parallel result in Seidman v. Fishburne-Hudgins Educational Foundation, Inc., 724 F.2d 413 (4th Cir. 1984), where the defendant lacked standing to object to a priest's voluntary disclosure. Practical effect: even when a survivor or accused would prefer disclosure, the clergyperson can unilaterally invoke the § 63.2-1509(A)(19)(ii) carveout and decline to report.

    View source ↗
  • Failure-to-report penalty graded at § 63.2-1509(D)

    Subsection (D) sets the penalty for non-reporting at a $500 fine for the first failure and not less than $1,000 for subsequent failures. Knowing and intentional failure to report rape, sodomy, aggravated sexual battery, or object sexual penetration is a Class 1 misdemeanor. The grading sits on the reporting floor itself; the privilege carveout in (A)(19)(i)–(ii) determines when that floor applies in the first place.

    View source ↗
Section 02What's needed

What it takes to close the gap.

Section 03How you can help

Concrete ways to support reform in Virginia.

Donate

Donate.

Donations fund Virginia-specific research and the long work of pressing on the § 63.2-1509(A)(19) doctrinal carveout state-by-state.

Mission supportDonate
Section 04Timeline

How Virginia got here.

  • 1984
    Seidman v. Fishburne-Hudgins (4th Cir.)

    Fourth Circuit applies Virginia privilege law and holds a civil defendant has no standing to object to a priest's voluntary disclosure, foreshadowing the privilege-allocation rule.

    View source ↗
  • 1996
    Nestle v. Commonwealth fixes privilege ownership

    Virginia Court of Appeals holds the clergy-penitent privilege belongs to the clergyperson, not the communicant. Controls who may invoke the § 63.2-1509(A)(19)(ii) carveout in practice.

    View source ↗
  • 2019-03
    HB 1659 / SB 1257 signed into law

    Identical companion bills from Del. Karrie K. Delaney and Sen. Jill Holtzman Vogel pass both chambers unanimously in February 2019 and are signed by Gov. Ralph Northam in March 2019. The carveout was written to protect the confessional; the Virginia Catholic Conference, which had backed the same proposal in 2006, supported the bills.

    View source ↗
  • 2019-07
    Clergy added to § 63.2-1509(A)(19), effective July 1

    Virginia's clergy mandatory-reporter duty takes effect, with the doctrinal-confidentiality and § 8.01-400 / § 19.2-271.3 cross-reference carveouts written into the same subsection.

    View source ↗
  • 2023-05
    HHS Children's Bureau confirms preserved-privilege posture

    The federal Child Welfare Information Gateway summary records Virginia as expressly naming clergy under § 63.2-1509 while preserving doctrinal confidentiality and the § 8.01-400 / § 19.2-271.3 privileges.

    View source ↗
Section 05Key cases

Litigation shaping the law.

  • Nestle v. Commonwealth

    22 Va. App. 336, 470 S.E.2d 133 (Va. Ct. App. 1996)1996

    Virginia Court of Appeals decision holding that the clergy-penitent privilege under Virginia law belongs to the clergyperson, not the communicant. The court found error in allowing a criminal defendant to invoke the privilege to refuse to divulge the contents of a confessional statement. Although Nestle predates the 2019 addition of clergy to § 63.2-1509, it controls who may invoke the privilege in any proceeding arising from a clergy disclosure, and therefore controls the practical reach of the § 63.2-1509(A)(19)(ii) carveout: the clergy member, not the survivor or the accused, decides whether the privilege is asserted.

    View source ↗
  • Seidman v. Fishburne-Hudgins Educational Foundation, Inc.

    724 F.2d 413 (4th Cir. 1984)1984

    Fourth Circuit decision applying Virginia privilege law in a civil action, holding that the defendant lacked standing to object to a priest's testimony about a confession the priest was willing to disclose. Reinforces the Nestle rule that the clergy-penitent privilege in Virginia is the clergy member's to invoke or waive, and that third parties cannot compel either disclosure or silence. Often cited alongside Nestle as the federal companion authority for the privilege-allocation rule that governs how the § 63.2-1509(A)(19)(ii) carveout operates in practice.

    View source ↗
Section 06Background

Public-record sources UCO is tracking.

Always verify against the underlying statute or filing before quoting.

  • Virginia General Assembly — Virginia Law (LIS)· May 2026
    § 63.2-1509. Requirement that certain injuries to children be reported by physicians, nurses, teachers, etc.; penalty for failure to report

    Operative principal statute. Subsection (A)(19) expressly names clergy as mandated reporters and writes the two-clause carveout in the same subsection: doctrinal confidentiality (clause i) and incorporation by reference of § 8.01-400 and § 19.2-271.3 (clause ii). Subsection (D) sets failure-to-report penalties.

    View source ↗
  • Virginia General Assembly — Virginia Law (LIS)· May 2026
    § 8.01-400. Communications between ministers of religion and persons they counsel or advise

    Civil clergy-penitent privilege statute incorporated by reference into § 63.2-1509(A)(19)(ii). Bars compelling testimony or disclosure of confidential communications made to qualifying clergy while the communicant was seeking spiritual counsel and advice.

    View source ↗
  • Virginia General Assembly — Virginia Law (LIS)· May 2026
    § 19.2-271.3. Communications between ministers of religion and persons they counsel or advise

    Criminal-action counterpart to § 8.01-400, also incorporated into the § 63.2-1509(A)(19)(ii) reporting carveout. Bars compelling clergy testimony in criminal actions regarding confidential communications from an accused seeking spiritual counsel.

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

    Federal state-statute summary confirming Virginia expressly names clergy under § 63.2-1509 and preserves confidentiality required by religious doctrine and the § 8.01-400 / § 19.2-271.3 privileges. Authoritative secondary cross-reference for both statusBucket and privilegePosture classifications.

    View source ↗
  • Virginia Legislative Information System (LIS)· 2019
    HB 1659 (2019 Regular Session) — Child abuse and neglect; mandatory reporters

    Official bill-summary page for the 2019 enactment that added clergy as the nineteenth category of mandated reporter under § 63.2-1509(A). Identical to SB 1257. Passed both chambers unanimously in February 2019; signed in March 2019; effective July 1, 2019. The bill summary itself describes the doctrinal-confidentiality and § 8.01-400 / § 19.2-271.3 carveouts.

    View source ↗
  • Victim Rights Law Center· September 2023
    Clergy Privacy FAQs — Virginia

    Practitioner brief synthesizing Virginia's two clergy-penitent privilege statutes, the § 63.2-1509 reporting regime, and the principal Virginia case law on privilege ownership (Nestle v. Commonwealth and Seidman v. Fishburne-Hudgins). Secondary corroboration that under Virginia law the clergyperson, not the communicant, holds and can assert the privilege.

    View source ↗
  • Virginia Legislative Information System (LIS)· 2019
    SB 1257 (2019 Regular Session), child abuse and neglect; mandatory reporters

    Official bill-summary page for the Senate companion to HB 1659; chief patron Jill Holtzman Vogel. Identical to HB 1659; passed both chambers and signed March 2019, effective July 1, 2019. Substantiates the Senate patron attribution.

    View source ↗
Last reviewed May 29, 2026 · by Unheard Child Org research teamHow we track this

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