NJ Supreme Court Quotes and Cites Prof. Ronald Colombo

In an important New Jersey Supreme Court case concerning the scope of the clergy-penitent privilege (NJ v. JG), dissenting Associate Justice Rivera-Soto extensively and approvingly quoted from Professor Ronald J. Colombo’s note, “Forgive Us Our Sins: The Inadequacies of the Clergy-Penitent Privilege,” 73 N.Y.U. L. Rev. 225 (1998).

Justice Rivera-Soto adopted Professor Colombo’s reasoning that the privilege should only protect communication “which a cleric is prohibited by the dictates of his religion from disclosing,” for only such communication enjoys an expectation of confidentiality rising to the level necessary to justify the privilege.