At times one of the defenses we will see in abuse cases is the
confidentiality of penance, which is that things were said to other
members of the clergy, but they are protected because they were as part
of the sacrament of penance.
http://stcloud.legalexaminer.com/property-owners-liability-slip-fall/archbishop-of-yorks-bold-suggestion-end-to-confidentiality-in-child-abuse-confessions/
http://stcloud.legalexaminer.com/property-owners-liability-slip-fall/archbishop-of-yorks-bold-suggestion-end-to-confidentiality-in-child-abuse-confessions/