In re: Church of Jesus Christ of Latter-Day Saints

Court of Appeals for the Tenth Circuit·Decided August 31, 2026·No. 25-4068·Published

Opinion

FILED

United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS August 31, 2026 Christopher M. Wolpert

FOR THE TENTH CIRCUIT Clerk of Court

In re: THE CHURCH OF JESUS CHRIST No. 25-4068 OF LATTER-DAY SAINTS TITHING LITIGATION

Appeal from the United States District Court for the District of Utah

(D.C. No. 2:24-MD-03102-RJS-DAO)

Scott A. George of Seeger Weiss, Philadelphia, Pennsylvania (Frazar W. Thomas; Christopher A. Seeger of Seeger Weiss, Ridgefield Park, New Jersey; Steven A. Schwartz of Chimicles Schwartz Kriner & Donaldson-Smith, Haverford, Pennsylvania; James E. Magleby and Yevgen Kovalov of Magleby Cataxinos, Salt Lake City, Utah; Martin Woodward of Kitner Woodward, Dallas, Texas; James J. Rosemergy of Carey Danis & Lowe, St. Louis, Missouri; Jacob A. Flint of Jacob Flint Law, St. Louis, Missouri; David B. Jonelis of Lavely & Singer, Los Angeles, California; and Todd S. Eagan of Eagan Law Corporation, Santa Monica, California with him on the briefs), for Plaintiffs-Appellants.

Paul D. Clement of Clement & Murphy, PLLC, Alexandria, Virginia (Andrew C. Lawrence and Nicholas A. Aquart; Randy T. Austin and Justin W. Starr of Kirton McConkie, Salt Lake City, Utah; Mark S. Mester of Latham & Watkins LLP, Chicago, Illinois; Jason R. Burt of Latham & Watkins LLP, Washington, D.C. with him on the briefs), for Defendants-Appellees.

Before HARTZ, PHILLIPS, and MORITZ, Circuit Judges.

HARTZ, Circuit Judge.

Plaintiffs brought this action against the Church of Jesus Christ of Latter-day Saints (the Church) and its subsidiary, Ensign Peak Advisors, Inc. (Defendants),

alleging that Defendants engaged in fraudulent conduct to induce Plaintiffs to donate to the Church. They also brought claims for breach of fiduciary duty and unjust enrichment and sought to represent a class of all persons in the United States who donated money to the Church after 1997. The district court granted Defendants’ motion to dismiss under Fed. R. Civ. P. 12(b)(6) on the ground that the complaints were untimely. It said that in light of news reports throughout the country Plaintiffs, had they exercised reasonable diligence, should have known of the scheme more than three years before they filed suit. We agree and affirm the dismissal.

I. BACKGROUND In reviewing a motion to dismiss, courts may consider only the well-pleaded allegations of the complaint, documents that the complaint incorporates by reference, documents referred to in the complaint that are central to the plaintiffs’ claims and whose authenticity is not challenged, and matters of which the court may take judicial notice. See Gee v. Pacheco, 627 F.3d 1178, 1186 (10th Cir. 2010). We assume the truth of the well-pleaded factual allegations of the complaint so long as they are not contrary to documents that the court can consider.

The Church receives substantial funds from tithes and other donations. Much of this money finances significant religious outreach and charitable work. But the Church also operates several secular businesses, such as a general-goods store near its Salt Lake City headquarters. And, more relevant to this case, the Church has said that it sets aside a portion of donations to invest and build a “prudent reserve for the future.” In re Church of Jesus Christ of Latter-day Saints Tithing Litig., (In re

Tithing Litig.) 785 F. Supp. 3d 1009, 1019 (D. Utah 2025) (internal quotation marks omitted). In 1997 it formed Ensign as a § 501(c)(3) nonprofit corporation. Ensign now manages a portfolio worth over $100 billion.

A. The Alleged Scheme We take our description of the alleged scheme from the allegations of the complaint.

Defendants concealed the size of Ensign’s portfolio to make the Church more attractive to potential donors. These donors were misled into believing that the Church promptly used donations for charitable purposes. One deceptive tactic that Ensign employed was to submit misleading documents to the SEC. The SEC required Ensign to file certain forms listing all public securities (not including cash or bonds) under its management. But Ensign created 13 shell LLCs throughout the country and filed the forms in the names of those entities, obscuring the fact that Ensign retained discretion over all investment decisions by the LLCs. Also, the Church used a complex web of entities to transfer funds to Ensign. Once funds reached Ensign, they were continually reinvested, not used for Church organizations or efforts.

This scheme ran counter to the Church’s public statements about how it used tithed funds. For example, the Church said it was not using tithes to pay for a Church effort to revitalize an area near the Church’s Temple Square by developing the City Creek Mall. The Church-owned Ensign magazine, which is available online, reported on this promise in its December 2003 and December 2006 issues, as did a 2012

article in The Salt Lake Tribune. Yet, between 2010 and 2014, Ensign spent $1.4 billion in donated funds on the construction of the City Creek Mall.

B. The 2019 Whistleblower Report In December 2019 a former Ensign employee and self-styled whistleblower published a “Letter to an IRS Director” (the Whistleblower Report) claiming that Defendants underreported the value of the Church’s assets and improperly directed tithing funds toward nonreligious commercial ventures.

Between December 2019 and February 2020 news outlets including The Wall Street Journal, The Washington Post, Forbes, Fox News, CNN, The Salt Lake Tribune, and Deseret News ran stories on the Whistleblower Report. The Church responded publicly, acknowledging that it maintains a reserve fund but arguing that it “complies with all applicable law governing . . . donations, investments, taxes and reserves.” Aplts. App., Vol. 1 at 64 (quoting The Church of Jesus Christ of Latter- day Saints, First Presidency Statement on Church Finances (Dec. 17, 2019), https://newsroom.churchofjesuschrist.org/article/first-presidency-statement-church- finances [https://perma.cc/A34K-ZQ2C]). According to Plaintiffs, “the IRS evidently found nothing of interest in the Whistleblower Report.” Aplts. Br. at 23.

But three suits by current and former Church members soon followed, incorporating allegations based on the Whistleblower Report. Huntsman v. Corp. of the President of the Church of Jesus Christ of Latter-day Saints, 2021 WL 4296208, at *3 (C.D. Cal. Sept. 10, 2021), filed in March 2021, raised a fraud claim based on misuse of tithing funds and alleged that the plaintiff discovered the fraud in

December 2019 after learning of the Whistleblower Report. See Compl. at 5, Huntsman, 2021 WL 4296208 (No. 2:21-cv-2504) (hereinafter Huntsman Compl.). Cook v. Corp. of the President of the Church of Jesus Christ of Latter-Day Saints, No. 2:20-cv-80 (D. Utah Feb. 10, 2020), filed in February 2020, asserted a fraud claim against the Church for failing to abide by the teachings of the Book of Mormon, and cited a December 2019 Washington Post article about the Whistleblower Report. Compl. at 5–6, 8, Cook, No. 20-cv-80 (hereinafter Cook Compl.). And Gaddy v. Corp. of the President of the Church of Jesus Christ of Latter-Day Saints, 665 F. Supp. 3d 1263, 1272–73 (D. Utah 2023), filed before the Whistleblower Report’s publication, alleged a scheme to conceal facts about Mormon history from lay members and was amended soon after publication of the Report to allege misuse of tithing funds. See Proposed Am. Class Action Compl. at 2–3, Gaddy, 665 F. Supp. 3d 1263 (No. 19-cv-554) (hereinafter Gaddy Proposed Am. Compl.).

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