Diocese of Fresno: 153 Abuse Claims Force Fourth Northern California Diocesan Bankruptcy

The Roman Catholic Bishop of Fresno—the California corporation sole representing a Central California diocese serving approximately 949,000 Catholics across eight counties, 87 parishes, and 21 Catholic schools—filed for chapter 11 bankruptcy on July 1, 2025. The filing came after more than 150 sexual abuse claims filed under California's Child Victims Act added pressure to the diocese's finances. With approximately $50 million to $100 million in both assets and liabilities, the Fresno diocese became the fourth Northern California diocese to seek bankruptcy protection amid a national wave of clergy abuse litigation that has produced over $5 billion in total payouts since 2004.

The bankruptcy came nearly one year after Bishop Joseph V. Brennan initially announced bankruptcy plans in May 2024, with the delay attributed to accounting staff turnover, closure of a Wells Fargo bank account, and preparation for federal reporting requirements. That year-long delay drew sharp criticism from survivors' attorneys, who filed motions asking the court to investigate whether the diocese deliberately misled survivors by claiming for 14 months that filing was "imminent." The case involves mass tort liability, religious institution governance, and the requirement for Vatican approval before a Catholic diocese may file for bankruptcy.

Central California's Catholic Diocese

The Diocese of Fresno is the Catholic diocese for Central California, with operations across the Central Valley and surrounding regions. The diocese includes parishes, schools, and other ministry operations overseen by the Roman Catholic Bishop of Fresno.

Geographic and demographic scope. The diocese covers eight counties in Central California—Fresno, Inyo, Kern, Kings, Madera, Merced, Mariposa, and Tulare—spanning more than 35,000 square miles. The diocese ministers to approximately 949,000 Catholics. The religious infrastructure includes a network of 87 parishes and 21 Catholic schools.

Corporation sole structure. The secular embodiment of the Diocese of Fresno is the Roman Catholic Bishop of Fresno, a California corporation sole ("RCBF"). A corporation sole is a legal entity consisting of a single incorporated office occupied by one person—in this case, the bishop. The RCBF is the only entity filing for chapter 11; individual parishes, schools, and affiliated organizations are separate legal persons not included in the bankruptcy proceeding.

Financial position. The diocese reported FY2024 operating revenue of approximately $42.3 million. The diocese carries a debt of approximately $30.3 million owed to the Deposit & Loan Fund as of May 31, 2025. The Deposit & Loan Fund is an internal diocesan lending mechanism through which parishes and other entities deposit excess funds and borrow for capital projects. The bankruptcy schedules listed assets and liabilities each in the $50 million to $100 million range, with between 1,000 and 5,000 creditors.

California AB 218 and the Abuse Claims

California's Child Victims Act enabled survivors to bring previously time-barred claims against institutions, including Catholic dioceses. The Fresno diocese faced claims from decades past that had been barred by statutes of limitations until the legislature enacted the revival window.

The AB 218 revival window. California's Assembly Bill 218 (the Child Victims Act), signed into law in October 2019, created a three-year revival window from January 1, 2020 through December 31, 2022 that allowed survivors of childhood sexual abuse to file claims regardless of when the abuse occurred. Before AB 218, California's statute of limitations generally required claims to be filed before the victim's 26th birthday. AB 218 extended the prospective statute of limitations from age 26 to age 40. The law also allows courts to award triple damages in cases where evidence of a cover-up exists.

Claims against the diocese. Approximately 160 sexual abuse claims were filed naming the diocese, with seven resolved through mediation before the bankruptcy filing and approximately 153 remaining pending at the time of filing. Many claims stem from abuse that occurred decades ago, with the 2021 publication of the diocese's list of approximately 50 "credibly accused" clergy members followed by additional claims. The claims were filed during the AB 218 revival window, which closed on December 31, 2022, while claims by survivors under 40 can still proceed under the extended prospective statute.

Constitutional challenges failed. California's Catholic bishops attempted to challenge AB 218 as unconstitutional in January 2021, arguing that the revival window violated due process protections and unfairly targeted religious institutions. Alameda Superior Court Judge Winifred Y. Smith rejected these arguments on April 29, 2021, finding the law constitutional. The U.S. Supreme Court subsequently declined to review the petition, leaving the Child Victims Act in effect.

The One-Year Delayed Filing

The diocese's path to bankruptcy included a year-long delay between the initial announcement and actual filing, drawing criticism from survivors' advocates and prompting motions seeking court investigation into potential bad faith.

Initial announcement. In May 2024, Bishop Joseph V. Brennan announced via open letter that the diocese intended to file for bankruptcy, initially targeting an August 2024 filing date. Brennan described the decision as part of a "journey of conversion through contrition" and articulated two primary goals: handling abuse claims with "equitable compassion" and ensuring the continuation of ministry throughout the diocese. He acknowledged that "the faithful may be dismayed by the news of our serious financial situation" but asked parishioners to "let go of their distress and turn their hearts towards the victims of abuse."

Delay and explanation. The filing was delayed by approximately one year, with the actual petition filed on July 1, 2025. At the four-hour 341 meeting of creditors on August 11, 2025, Bishop Brennan testified under oath that the delay resulted from "unforeseen issues." Specifically, Brennan cited the closure of a Wells Fargo bank account and the departure of three consecutive controllers from the diocese's accounting department. Brennan stated that diocesan leaders did not want to file until confident they could comply with federal bankruptcy reporting standards. The bishop described the process as "long, painful and difficult."

Vatican approval requirement. Catholic dioceses require Vatican approval before filing for bankruptcy. The Diocese of Fresno received formal Vatican approval in June 2025, permitting the July 1 filing.

Survivors' criticism and investigation motion. The filing delay drew sharp criticism from survivors' attorneys. Attorney Rick Simons filed a motion asking the court to investigate whether the diocese deliberately misled the court and survivors by claiming for 14 months that a bankruptcy filing was "imminent." Attorney Jennifer Stein of Jeff Anderson & Associates criticized the filing as "a decision rooted in self-preservation over the protection of children and righting the wrongs of the Diocese."

Chapter 11 Case Developments

The bankruptcy proceeding has advanced through first-day orders, professional retentions, and several contested matters while the diocese works toward establishing a survivors' compensation fund.

341 Meeting of creditors. The meeting of creditors under Section 341 was held on August 11, 2025 and lasted four hours. Bishop Brennan appeared and testified under oath regarding diocesan finances, assets, workforce, insurance policies, and bank accounts. Topics covered included the structure of the Deposit & Loan Fund, real property holdings, insurance coverage, and the circumstances of the one-year filing delay. Brennan testified about the accounting staff departures and Wells Fargo account closure.

Professional retentions. The debtor retained McCormick, Barstow, Sheppard, Wayte & Carruth LLP as lead bankruptcy counsel. FTI Consulting, Inc. serves as financial advisor to the debtor, and its retention was approved on November 10, 2025. Blank Rome LLP was retained as insurance counsel. Stinson LLP serves as special counsel. The U.S. Trustee filed objections to professional fee applications in early December 2025, and the professionals responded with declarations and voluntary fee reductions.

Insurance disputes. Certain London Market Insurance Companies and domestic insurers objected to confidentiality protocols proposed by the debtor and the Official Committee of Unsecured Creditors. The debtor and UCC filed responses to the insurance objections, and a confidentiality agreement was approved in December 2025.

Exclusivity extension. The debtor filed a motion to extend exclusivity in October 2025, which was granted on November 17, 2025. Exclusivity refers to the statutory period during which only the debtor may file a chapter 11 plan.

Claims process. Angeion Group serves as claims agent for the bankruptcy, administering a portal for creditors and claimants to file proofs of claim and access case information. Survivors become unsecured creditors in the bankruptcy proceeding and are represented by an Official Committee of Unsecured Creditors appointed by the U.S. Trustee. A compensation fund will be established as part of the chapter 11 plan to pay validated claims through a court-approved process.

Catholic Diocesan Bankruptcies: National Context

The Fresno bankruptcy is part of a national wave of Catholic diocesan filings triggered by extended statutes of limitations and abuse claim revival windows across multiple states.

National statistics. According to research by Penn State Dickinson Law, as of November 2025, 42 U.S. Catholic religious organizations have sought bankruptcy protection in chapter 11, with 28 cases concluded and 14 pending. Professor Marie T. Reilly maintains a database tracking these filings. Total payouts from U.S. Catholic dioceses for abuse claims since 2004 have exceeded $5 billion.

Major settlements. The Archdiocese of Los Angeles agreed to pay more than $880 million to over 1,300 abuse survivors. The Diocese of Rockville Centre, New York reached a $323 million settlement with approximately 600 victims. The Archdiocese of New Orleans reached a $230 million bankruptcy settlement, followed shortly by the filing of the Diocese of Alexandria, Louisiana on October 31, 2025.

California dioceses. Four dioceses in Northern California have filed for bankruptcy protection: Sacramento, Oakland, the Archdiocese of San Francisco, and now Fresno. Each filing followed the AB 218 revival window that enabled previously time-barred claims.

Bankruptcy as strategy: debate continues. Survivors' advocates have long debated whether diocesan bankruptcy helps or harms abuse survivors. The bankruptcy process consolidates all claims into a single federal proceeding, and survivors become creditors. Attorney Rick Simons noted that "a lot of people lose their rights because of this, and they lose it either for very minimal compensation."

Key Timeline

Frequently Asked Questions

Why did the Diocese of Fresno file for bankruptcy?

The diocese filed for chapter 11 bankruptcy to address more than 150 sexual abuse claims filed against clergy under California's Child Victims Act (AB 218), which opened a three-year revival window for previously time-barred claims. With approximately 153 pending claims, bankruptcy allows the diocese to consolidate claims into a single proceeding and establish a compensation fund for survivors. Bishop Brennan described the bankruptcy as necessary to handle claims with "equitable compassion" while ensuring the continuation of the diocese's religious and educational mission.

What is California AB 218?

AB 218, the California Child Victims Act, was signed into law in October 2019 and created a three-year revival window from January 1, 2020 through December 31, 2022 allowing survivors of childhood sexual abuse to file claims regardless of when the abuse occurred. The law also extended the prospective statute of limitations from age 26 to age 40 for future claims and permits courts to award triple damages where evidence of a cover-up exists. This revival provision enabled thousands of previously time-barred claims to proceed against California institutions, including multiple Catholic dioceses.

Why was the filing delayed by one year?

Bishop Brennan announced bankruptcy plans in May 2024 with an August 2024 target date, but the actual filing occurred on July 1, 2025. At the 341 meeting, Brennan testified the delay resulted from "unforeseen issues" including closure of a Wells Fargo bank account and the departure of three consecutive controllers from the diocese's accounting department. Diocesan leaders stated they did not want to file until confident they could comply with rigorous federal bankruptcy reporting standards. The diocese also needed to obtain Vatican approval, which was received in June 2025. Survivors' attorneys have challenged this delay and filed motions seeking investigation into whether the diocese acted in bad faith.

What is a corporation sole?

A corporation sole is a legal entity consisting of a single incorporated office occupied by a single person—in this case, the Roman Catholic Bishop of Fresno ("RCBF"). Under this structure, all diocesan property is vested in the bishop as a legal entity distinct from his personal capacity. When bishops change through retirement, reassignment, or death, the corporation sole continues with the successor. The RCBF is the only entity in bankruptcy; individual parishes, schools, and affiliated organizations are separate legal persons not included in the proceeding.

Why was Vatican approval required?

Catholic dioceses operate under canon law and require Vatican approval before filing for bankruptcy. The Diocese of Fresno received formal Vatican approval in June 2025, permitting the July 1, 2025 filing.

How many abuse claims are involved?

Approximately 160 sexual abuse claims were filed against the diocese, with 7 resolved through mediation before the bankruptcy filing and approximately 153 remaining pending at the time of filing. Claims relate to abuse by approximately 50 clergy members on the diocese's "credibly accused" list published in 2021. The claims were filed during the AB 218 revival window and represent the core liability driving the bankruptcy.

What happens to abuse survivors in bankruptcy?

Survivors become unsecured creditors in the bankruptcy proceeding and are represented by an Official Committee of Unsecured Creditors appointed by the U.S. Trustee. A compensation fund will be established as part of the chapter 11 plan to pay validated claims through a court-approved process. While bankruptcy can provide more equitable distribution among survivors compared to individual litigation outcomes, survivors' advocates have criticized the process for limiting individual recoveries and forcing claimants to accept reduced settlements.

Is this the first California diocese to file bankruptcy?

No. Fresno is the fourth Northern California diocese to file for bankruptcy protection. Sacramento, Oakland, and the Archdiocese of San Francisco previously filed following the AB 218 revival window.

How does this compare to other Catholic bankruptcies nationally?

As of November 2025, 42 U.S. Catholic religious organizations have sought chapter 11 protection, with total payouts exceeding $5 billion since 2004. Notable settlements include the Archdiocese of Los Angeles ($880+ million to 1,300+ survivors) and the Diocese of Rockville Centre ($323 million to approximately 600 survivors).

What is the current status of the case?

The case is in early stages with professional retentions approved, exclusivity extended through the November 2025 order, and confidentiality protocols established with insurers. No plan or disclosure statement had been filed as of late December 2025.

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