Sexual grooming is a documented feature of clergy sexual abuse. Yet in much of the United States, the law still struggles to address grooming before abuse occurs. That needs to change.
A 2022 peer-reviewed study examined records involving 10,667 alleged child sexual abuse cases in the U.S. Catholic Church. Researchers found that accused clergy frequently used grooming tactics involving access and isolation, trust development, and gradual desensitization to inappropriate behavior.
The study does not establish how prevalent grooming is among clergy generally. But it does demonstrate that grooming is a recognizable component of documented abuse allegations, not merely a theoretical concern.
And that raises an obvious question: Why should the law have to wait until a child is sexually abused before it can intervene?
The problem starts before the abuse
Grooming often begins with behavior that appears innocent: special attention, gifts, private conversations, or unusually close relationships. Over time, an offender may cultivate secrecy, undermine boundaries, and exploit a child’s trust.
In religious settings, spiritual authority can make these tactics particularly effective.
A 2020 study of religious duress and reverential fear examined how victims’ respect for clergy can inhibit resistance, disclosure, and escape from abusive relationships.
The implications are troubling. A child may trust the offender precisely because the church has taught the child to do so. Parents may similarly assume that a respected religious leader is safe.
By the time sexual abuse occurs, the offender may already have spent months or years manipulating the child and the surrounding adults.
Criminalizing grooming before abuse occurs
The United States has a patchwork of laws addressing grooming. Some states have established standalone offenses, while federal law addresses certain conduct through statutes governing enticement and attempted sexual exploitation. But coverage varies considerably by jurisdiction and conduct.
The Enough Abuse Campaign’s March 2026 legislative survey identified 15 states that criminalized grooming as a felony, with significant differences in their definitions and scope. Its subsequently updated legislative overview identifies 18 states.
An established international model exists for addressing the problem.
Following its extensive investigation into institutional child sexual abuse, Australia’s Royal Commission into Institutional Responses to Child Sexual Abuse recommended broad criminal offenses covering conduct intended to groom children for sexual abuse.
Importantly, the commission also recommended criminalizing the grooming of parents, caregivers, and others whose trust offenders manipulate to gain access to children.
The distinction is critical: The law need not wait for completed sexual abuse when prosecutors can prove deliberate conduct undertaken with the intent to facilitate it.
What effective legislation requires
Not all anti-grooming laws are created equal. Some are little more than feel-good legislation, criminalizing conduct that is already illegal, such as transmitting child sexual abuse material (CSAM), while failing to address the broader pattern of manipulation that precedes abuse.
Indeed, the Enough Abuse Campaign’s legislative analysis identifies statutes that address narrowly defined conduct while leaving other grooming behaviors outside their scope.
An effective law must recognize that grooming is often a pattern and practice, not an isolated incident. Much like the federal Racketeer Influenced and Corrupt Organizations Act (RICO), which recognizes patterns of related criminal activity, grooming legislation should permit courts to evaluate a course of conduct rather than examining each incident in isolation.
That might include repeated boundary violations, deliberate isolation, secrecy, manipulation of parents, and exploitation of religious authority. Individually, some of these behaviors may be lawful. Collectively, when accompanied by provable intent to facilitate sexual abuse, they may establish grooming.
Of course, the law must distinguish deliberate grooming from ordinary mentoring, pastoral care, and legitimate relationships. Criminal liability should require proof beyond a reasonable doubt of clearly defined conduct and the requisite criminal intent.
But criminal penalties alone are insufficient. Effective legislation should also:
- Establish a private civil cause of action. Children and their legal representatives should be able to seek civil remedies for grooming, without waiting for criminal prosecution or a completed sexual assault. Appropriate relief could include damages for proven injuries, injunctive relief, and recovery of legal fees where authorized.
- Expressly authorize protective orders. Courts should be empowered to issue protective orders based on credible, specific allegations of grooming when the applicable evidentiary standard and risk requirements are satisfied. Such orders could prohibit contact with a child, restrict unsupervised access, or impose other narrowly tailored safeguards. Emergency relief should be available when necessary, subject to prompt judicial review and due-process protections.
- Cover in-person and online conduct. Grooming does not require a smartphone, an internet connection, or explicit sexual communications. Legislation should address the conduct itself, including exploitation of positions of trust and authority.
Protective orders are particularly important. They offer a mechanism for intervention before a child is harmed, rather than leaving parents and safeguarding officials to wait for a criminal prosecution—or worse, a completed sexual assault.
The objective is not to criminalize awkward relationships or innocent conduct. It is to recognize deliberate patterns of predatory behavior, provide meaningful civil remedies, and give courts the authority to protect children before abuse occurs.
Churches cannot be trusted to handle this alone
Churches have safeguarding policies, disciplinary procedures, and elaborate assurances about protecting children. Yet the history of institutional abuse demonstrates how easily those systems can fail when reputations, personal loyalties, and clerical authority take precedence over safeguarding.
And people being people, some parishioners will defend their priest with a fervor that borders on the irrational. Apparently, protecting Father Wonderful’s reputation is more important than protecting a child. Never mind that the allegations may be credible, the warning signs obvious, and the consequences potentially devastating.
Indeed, the Australian Royal Commission’s investigation of religious institutions documented systemic failures to respond appropriately to child sexual abuse allegations, including failures involving institutional accountability, reporting, and the protection of children.
That is precisely why safeguarding cannot depend on whether a congregation likes its priest, whether the vestry wants to avoid controversy, or whether the bishop finds the allegations inconvenient.
Internal disciplinary systems are no substitute for criminal law. Nor should religious organizations enjoy special exemptions from laws designed to protect children.
For Anglican Watch, the conclusion is straightforward: Grooming intended to facilitate child sexual abuse should be a clearly defined criminal offense, whether it occurs in a classroom, a sports program, a church, or anywhere else.
Children should not have to become victims of completed sexual abuse before the law recognizes the danger.
And churches that genuinely prioritize safeguarding should have no difficulty understanding why. If protecting children requires someone outside the church to intervene, that says rather a lot about the church.
Sources
- Winters, Georgia M., Elizabeth L. Jeglic, and Karen J. Terry. “The Prevalence of Sexual Grooming Behaviors in a Large Sample of Clergy.” Sexual Abuse, 2022.
- Spraitz, Jason D., and Kendra N. Bowen. “Religious Duress and Reverential Fear in Clergy Sexual Abuse Cases: Examination of Victims’ Reports and Recommendations for Change.” Criminal Justice Policy Review, published online 2020.
- Enough Abuse Campaign: Grooming Legislation as of March 2026. State-by-state legislative survey.
- Enough Abuse Campaign: Grooming Children for Sexual Abuse — State Legislation. Updated legislative overview.
- Australian Royal Commission into Institutional Responses to Child Sexual Abuse: Criminal Justice. Recommendations concerning grooming offenses.
- Australian Royal Commission into Institutional Responses to Child Sexual Abuse: Religious Institutions. Findings concerning institutional failures and child protection.
- 18 U.S.C. § 1961: Racketeer Influenced and Corrupt Organizations Act (RICO), definitions. Federal statutory treatment of patterns of racketeering activity.
- United States Sentencing Commission: Primer on RICO Offenses (2025). Discussion of related conduct, continuity, and the requirements for establishing a pattern.
