Commonwealth of Pennsylvania v. Lynn

William Lynn (defendant) was the Secretary for Clergy for the Roman Catholic Archdiocese of Philadelphia. As secretary, Lynn was responsible for clergy assignments and for investigating and addressing claims of child sexual abuse involving clergymen. To help with child sexual-abuse investigations, Lynn had access to the archdiocese’s secret archive containing all allegations made against clergymen. Using that archive, Lynn compiled a list of 35 active-duty clergymen accused of sexually abusing children, including Reverend Edward Avery, a pedophile with a long history of sexual misconduct with minors. Lynn did not investigate the allegations on the list and did not restrict the 35 active-duty clergymen from interacting with children. Over the many years Lynn served as Secretary of Clergy, Lynn received multiple, credible reports of past child sexual abuse involving either Avery or one of the other 35 active-duty clergymen on Lynn’s list. Lynn did not meaningfully investigate any of those reports. Even though Lynn knew Avery was a child molester, Lynn assigned Avery to St. Jerome’s, a church with an attached elementary school. While at St. Jerome’s, Avery sexually assaulted D.G., a 10-year-old student, on multiple occasions. After almost a decade of investigating allegations of sexual abuse within the archdiocese, the Commonwealth of Pennsylvania (plaintiff) charged Lynn with endangering the welfare of a child, arguing that Lynn endangered D.G. by assigning Avery, a known child molester, to St. Jerome’s. At trial, the commonwealth submitted extensive evidence that Lynn had known about, and had disregarded, credible claims of sexual abuse against Avery and numerous other clergymen under Lynn’s supervision. The trial court convicted Lynn. Lynn appealed, and the appellate court reversed, holding that Lynn could not be held liable for endangering D.G. because he did not directly supervise D.G. The commonwealth appealed, arguing that Lynn, as Secretary of Clergy, had supervisory authority over the welfare of all children in the archdiocese.