Abuse by a Sunday School Teacher, Deacon or Church Volunteer

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Much church abuse is committed not by clergy but by volunteers and lay leaders: Sunday school teachers, nursery workers, deacons, choir directors, bus drivers and mentors. A church that recruits and supervises volunteers owes children the same duty of care as it does with paid staff, and can be liable when it fails to screen, supervise or act on warnings.

Facts checked September 18, 2026. Sources are listed at the end of this page.

How common is abuse by church volunteers?

In 2007 the three insurers that cover most Protestant churches in the United States told the Associated Press they typically received more than 260 reports a year of young people being sexually abused by clergy, church staff, volunteers or congregation members. The insurers noted that a report is not proof of guilt, but the figures show that abuse is not limited to clergy.

What churches should do to protect children

  • Background checks and reference checks before anyone works with children
  • A waiting period before new members can volunteer with children
  • Two adults present at all times, with windows in classroom doors
  • Rules on transport, sleepovers and one-on-one contact
  • Training on grooming and a clear way to raise concerns
  • Removing volunteers and reporting to authorities when abuse is suspected

How a church’s safeguards affect an abuse claim

SafeguardWhy it matters in a claim
Background checkFailing to check, or ignoring what a check showed, is strong evidence of negligent selection
Two-adult ruleLetting a volunteer be alone with children breaches a basic safeguard
Written policies and trainingPolicies the church wrote but did not follow show it knew the risk
Response to complaintsIgnoring complaints or moving a volunteer quietly supports negligent retention and cover-up claims
State Law Notice: Laws governing civil claims for religious institution abuse vary significantly by state. Filing deadlines, lookback windows, and available defendants differ depending on where the abuse occurred and your current state of residence. The information on this page is general in nature. It does not constitute legal advice and should not be relied upon without first speaking to a qualified attorney about your specific circumstances.

Frequently Asked Questions

Can I sue a church for abuse by a Sunday school teacher?
Yes, in many cases. The church can be liable if it failed to screen or supervise the teacher, let them be alone with children, or ignored warning signs or complaints.
Is a church responsible for abuse by a volunteer?
It can be. Churches owe the same duty to protect children from volunteers they recruit and supervise as from paid staff. Being unpaid does not remove that duty.
Can I sue for abuse by a deacon or church elder?
Yes. Deacons and elders hold positions of trust, and the church or denomination that appointed and oversaw them may be liable alongside the abuser.
What if the abuse happened in the church nursery or daycare?
Church nurseries and daycare programmes owe a high standard of care to very young children. If the programme was licensed, state childcare rules may also apply. Keep any records you have and get advice.
Did the church have to run a background check on volunteers?
Requirements vary by state and denomination, but screening people who work with children is widely treated as a basic safeguard. Skipping it, or ignoring what it showed, supports a negligence claim.
How common is abuse by church volunteers?
More common than many people think. In 2007 the three largest Protestant church insurers reported receiving more than 260 reports a year of children being sexually abused by clergy, staff, volunteers or members.

See all frequently asked questions

Related pages

Sources

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