Federal Court Clears Trafficking and Abuse Claims Against LDS Church to Proceed

In a landmark ruling issued August 4, 2025, a federal judge in the Northern District of New York allowed key sex trafficking and abuse claims to move forward against The Church of Jesus Christ of Latter-Day Saints, rejecting the Church’s attempt to dismiss the case brought by three male plaintiffs who allege childhood sexual abuse by a former Church member.

Key Takeaways:

• TVPRA claims by one plaintiff (Ballantyne) survive dismissal.

• Church faces civil liability as both a perpetrator and beneficiary of sex trafficking.

• Court grants plaintiffs permission to amend with new claims under NYC’s GMVA and TVPRA obstruction provisions.

The Allegations: Systemic Abuse, Concealment, and Trafficking

According to the complaint, plaintiffs Alan and Michael Kitler and Kresten Ballantyne were sexually abused for years by Ronald Boyce, a Church member and authority figure who had been disciplined in Utah for prior abuse but was allegedly relocated to Schenectady, New York, by the Church to avoid legal accountability.

All three plaintiffs allege a pattern of grooming, coercion, and abuse facilitated by the Church’s assignment of Boyce as a “mentor” or “father figure.” The complaint alleges the Church knowingly enabled the abuse by failing to warn families, providing financial support that funded the exploitation, and discouraging victims from reporting to law enforcement.

The Legal Claims: TVPRA, Negligence, and Emotional Distress

The plaintiffs brought claims under both federal and state law:

• TVPRA (Trafficking Victims Protection Reauthorization Act): Only Ballantyne’s claims survived, as the Kitlers’ abuse occurred before a private right of action was added to the statute.

• Intentional Infliction of Emotional Distress (IIED): Allowed to proceed against the Church but dismissed against others.

Court’s Reasoning: Knowledge, Participation, and Benefit

The court found Ballantyne’s claims met all four prongs of a civil trafficking claim under the TVPRA:

1. Venture: Boyce’s abuse constituted a venture in sex trafficking.

2. Knowledge: The Church allegedly knew or should have known about Boyce’s conduct based on prior reports and excommunication history.

3. Participation: The Church not only reassigned Boyce but allegedly channeled aid through him, empowering his access to victims.

4. Benefit: The Church allegedly received financial and reputational benefit through labor, donations, and avoidance of scandal.

The court also allowed Ballantyne’s perpetrator liability claim under the TVPRA to proceed—an unusually high bar for institutional defendants—citing the Church’s alleged knowledge and facilitation of abuse.

What’s Next?

The plaintiffs now have leave to amend their complaint to add:

• A Gender Motivated Violence Act (GMVA) claim under NYC law against Boyce.

• A TVPRA obstruction claim against the Church, based on allegations that it blocked police investigations in 2015 by invoking clergy-penitent privilege.

The individual defendants, including bishops and teachers named in the suit, have been dismissed without prejudice, leaving the Church and Boyce as the primary defendants moving forward.

Legal Insights: Lessons for Institutions and Survivor Counsel

This decision reflects a growing trend in federal courts to interpret the TVPRA broadly, especially where religious or nonprofit institutions are accused of enabling abuse:

• Tolling Agreements Must Be Specific: Non-signatories can’t be bound unless clearly authorized or involved.

• “Knew or Should Have Known” = Constructive Knowledge: Courts are willing to infer knowledge from circumstantial evidence, especially in clergy abuse cases.

• Civil Trafficking Theories Can Pierce the Institutional Veil: The Church’s active role in reassigning and shielding Boyce from accountability tipped the balance.

Bottom Line

This ruling paves the way for broader civil liability against institutions under the federal trafficking statute, not just for direct abusers but for those who enable, ignore, or benefit from systemic sexual exploitation. Religious institutions, nonprofits, and youth organizations would be wise to review internal reporting procedures, clergy assignments, and legal risk exposure in light of this case.

For survivors seeking justice, this case signals a new frontier in institutional accountability. For attorneys, it underscores the power of the TVPRA when used strategically.