Craig McNeil Ford

Sources

1. Mormon church accused of failing to report child sex abuse in OR and WA; faces $25M suit, OregonLive.com (The Oregonian), February 10, 2025.
2. Julie Doe v. Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints et al, PACER - U.S. District Court - District of Oregon (federal), February 10, 2025.

• 1. Mormon church accused of failing to report child sex abuse in OR and WA; faces $25M suit

  • 20250210
  • News article
  • OregonLive.com (The Oregonian)

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  A woman who was sexually abused as a girl by her adopted father is suing The Church of Jesus Christ of Latter-day Saints, alleging a bishop from a Vancouver branch they attended was informed of the abuse but failed to report it to police or child welfare workers.

  As a result, the girl suffered additional months of abuse when the adopted parents split and the father, Craig McNeil Ford, took the girl to live with him in Oregon, according to the suit.

  It wasn’t until a biological daughter passed a note to a classmate alluding to the sexual abuse that police got involved, leading to the father’s arrest and convictions in Clark County in Washington and Linn County in Oregon.

  Ford, now 40, is in custody at Snake River Correctional Institution in eastern Oregon, serving a 33-year prison term.

  “He was 30 when he decided to take everything from a damaged, scared, broken 15-year-old girl,” the victim, identified in the suit as Julie Doe, wrote in a statement to a judge in 2022.

  The lawsuit, filed Monday in federal court in Eugene, accuses the Mormon church of negligence and seeks $25 million in damages. It is the latest lawsuit that accuses the church of burying information involving suspected child sex abuse.

  The suit alleges the church concealed from authorities the danger that one of its members posed, failed to protect the 15-year-old from abuse and failed to train its leaders how to properly respond to reports of child sexual abuse.

  “A teenaged girl should not have been repeatedly sexually abused for months in two separate states if church leaders had information to stop it,” said attorney Peter Janci, who filed the suit on behalf of the victim.

  “This case raises important questions about what appears to be continuing, systemic and widespread failures by the Mormon Church in responding to reports of child sexual abuse,” Janci said in a statement.

  A church spokesperson didn’t immediately respond to the allegations, but the church’s website says, “The Church’s position is that abuse cannot be tolerated in any form and that those who abuse will be accountable before God.”

  The site adds: “The Lord expects us to do everything we can to prevent abuse and to protect and help victims. No one is expected to endure abusive behavior.”

  Ford pleaded guilty in 2021 in Linn County Circuit Court to four counts of first-degree rape and one count of incest. In 2022, he pleaded guilty to four more counts of rape and incest in Clark County Superior Court. Those two cases involved Julie Doe. He also was convicted in 2018 for incest and child molestation in Clark County for sexually abusing another foster girl who was later adopted by Ford and his wife, Jenny Ford. The couple had four children, including the two adopted daughters.

  Ford is accused of groping and raping Julie Doe starting when she was 15, the suit says.

  She had been placed as a foster child in the couple’s Ridgefield, Washington, home in June 2013. They adopted her a year later and then in 2015 adopted another girl. The family regularly attended a Mormon church ward in a stake near Ridgefield.

  The suit says in 2016 the other foster girl in the home discovered more than a dozen sexual messages that Ford addressed to Julie Doe and showed them to Ford’s wife.

  Jenny Ford didn’t alert police but sent all four children in the home to stay with relatives in Montana and reported her husband’s sexual abuse to Wade Pickett, a Mormon bishop and stake president, according to the suit.

  Pickett didn’t report the abuse and didn’t advise Jenny Ford to report it to authorities, the suit alleges.

  Within weeks of the report to Pickett, Pickett learned that Craig Ford had picked up Julie Doe from Montana and took her to live with him alone in Albany as the parents separated, the suit says.

  Both Craig Ford and Julie Doe participated in church services and programs in the Albany area and church representatives visited Ford’s apartment, where the girl told one of the church officials that she had a “difficult secret” she wanted to share but was having trouble doing so, according to the suit.

  The church’s Albany ward bishop was concerned “something was amiss” within the household but took no action and Craig Ford lived in Albany with the girl from April 2016 through spring 2018 while sexually abusing her almost daily, the suit alleges.
  Meanwhile, Jenny Ford blamed the girl and encouraged her to commit suicide, the suit alleges.

  Police learned of the abuse in 2016 after one of the couple’s biological daughters shared a note with a classmate that read, “I wish my teacher knew that we think my dad had sex with sister (;) want to talk to you.”

  The classmate brought the note home and showed it to her mother, who contacted Vancouver police. The police alerted the Washington Department of Social and Health Services and began an investigation.

  Pickett acknowledged to police that he had been informed by the girl’s adoptive mother that Ford was sexually abusing the teen and had been shown one or more of the incriminating messages, according to the suit.

  The Washington police investigation led to the 2018 prosecution of Craig Ford, accused of abusing another adopted daughter in Clark County. Julie Doe divulged her abuse later in the ongoing investigation, prompting additional prosecutions.

  Julie Doe’s lawsuit seeks $20 million in damages for her mental and emotional suffering and $5 million for her psychotherapy and medical treatment.

  Janci noted that Julie Doe suffered sexual and psychological abuse despite remarks by the church’s legal counsel in 2010 that the Mormon church’s child abuse prevention policies were “the gold standard” among religious organizations.

  Washington is one of a handful of states without a law making clergy mandatory reporters of child abuse and neglect. Two Democratic state lawmakers are trying again this year to require clergy members to report child abuse or neglect, including when it is disclosed to them by a congregant during confession.

  In Oregon, clergy members are on the list of public or private officials who are mandated reporters of child abuse, though they aren’t required to report the information if it was part of a privileged communication.

  In 2017 and 2018, The Church of Jesus Christ of Latter-day Saints reached settlements with four members of the Navajo Nation who said they were sexually abused as part of a now-defunct church-run foster program that placed thousands of American Indian children with Mormon families. A fifth suit was filed by a Navajo member who says that he was sexually molested three times in the 1980s by a church bishop who lived across the street from his foster family, twice at the bishop’s home and once at a church office.

  An AP investigation in 2023 described the management of a “secretive church Helpline,” phone number set up by the church for bishops to report instances of child sex abusenationwide. Church officials say that they don’t keep any records of the reports to the helpline, the AP reported.

• 2. Julie Doe v. Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints et al

  • 20250210
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  • PACER - U.S. District Court - District of Oregon (federal)

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  Case 6:25-cv-00222-MC Document 1 Filed 02/10/25 Page 1 of 21

  Peter B. Janci, OSB No. 074249
  peter@crewjanci.com
  Kendall M. H. Spinella, OSB No. 214446
  kendall@crewjanci.com
  CREW JANCI LLP
  9755 SW Barnes Rd Suite 430, Portland, OR 97225
  Tel: (503) 306-0224
  Of Attorneys for Plaintiff
  UNITED STATES DISTRICT COURT DISTRICT OF OREGON EUGENE DIVISION
  JULIE DOE, an individual proceeding under a pseudonym,
  Plaintiff, v.
  CORPORATION OF THE PRESIDING BISHOP OF THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, a Utah corporation sole; CORPORATION OF
  THE PRESIDENT OF THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, a Utah corporation sole; and, THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, a Utah corporation sole,
  Defendants.
  CASE NO. _________________
  COMPLAINT
  (Negligence)
  JURY TRIAL DEMANDED
  COMPLAINT
  COMES NOW the Plaintiff by and through her attorneys and hereby states and alleges as follows:
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  INTRODUCTION
  1.
  This case involves abuse of a minor allowed, permitted or encouraged by the Church of
  Jesus Christ of Latter-day Saints (the “LDS Church”) and its agents as set out below. The victim (Plaintiff) and the abusers were members of or participants in the LDS Church with whom the LDS Church had special relationships. Before many of the acts of abuse suffered by Plaintiff, the LDS Church learned through its agents that Plaintiff was being abused and that the circumstances indicated that the abuse would continue. By failing to respond in any way to repeated indications of sexual abuse of the minor Plaintiff, the LDS Church knowingly allowed and permitted the victim to be subjected to near-daily invasive sexual abuse and rape, as well as psychological abuse and mental cruelty which extended for months.
  PARTIES
  2.
  Plaintiff Julie Doe is an adult woman, a natural individual domiciled in Pierce County,
  Washington, and a citizen residing in Pierce County, Washington. Plaintiff was born in August of 2000. Plaintiff is a victim of severe and repeated child sexual abuse, psychological abuse, and mental cruelty and is proceeding under a pseudonym to protect her privacy based on concerns about humiliation and reprisal. Plaintiff’s identity has been shared with counsel for Defendants to facilitate their investigation and defense of this matter. Plaintiff’s need for anonymity outweighs any public interest in knowing Plaintiff’s identity.
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  3.
  At all time relevant to this complaint, Defendant Corporation of The Presiding Bishop of
  The Church of Jesus Christ of Latter-Day Saints (“Corporation of the Presiding Bishop”), was a corporation sole incorporated in the State of Utah, a citizen of the State of Utah, and had its principal place of business in the State of Utah. At all time relevant to this complaint, Defendant Corporation of The President of The Church of Jesus Christ of Latter-Day Saints (“Corporation of The President”) was a corporation sole incorporated in the State of Utah, a citizen of the State of Utah, and had its principal place of business is the State of Utah. The Church of Jesus Christ of Latter-day Saints is a Utah corporation sole, with its principal place of business in Salt Lake City Utah, and, on information and belief, is a successor an interest to the Corporation of the Presiding Bishop and Corporation of the President. Defendant Corporation of The Presiding Bishop, Defendant Corporation of The President, and The Church of Jesus Christ of Latter-day Saints will hereinafter be referred to collectively as “LDS Church”, “LDS Church Defendants,” or “Defendants.”
  JURISDICTION
  4.
  Federal diversity jurisdiction exists pursuant to 28 U.S.C. § 1332. As set out inparagraphs
  2 through 4, there is a complete diversity of citizenship among the parties. The amount in controversy, exclusive of interest in costs, exceeds the sum or value of $75,000.00.
  VENUE
  5.
  Venue is proper in the United States District Court for the District of Oregon, Eugene
  Division, pursuant to 28 U.S.C. § 1391(b)(2), because a substantial part of the events and/or Page 3 – COMPLAINT

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  omissions giving rise to the claims alleged herein occurred in Linn County, Oregon.
  FACTS
  The LDS Church (or “Mormon Church”)
  6.
  The Church of Jesus Christ of Latter-day Saints (the “LDS Church” or “Mormon
  Church”) is a hierarchically structured religious institution. At the top, the President of the LDS church is the “Divine Prophet, Seer and Revelator” and wields the highest level of authority within the LDS Church. The LDS President has the authority to appoint and remove anyone in the LDS church, including all members of local level organizations known as Wards and Stakes at will. He delegates responsibility through various corporations, unincorporated associations, and agents. The power and authority of the LDS President includes: the appointment of LDS Church officials; the promulgation of LDS Church policy and procedures; the management of LDS Church property and assets; the conduct of Church-controlled corporations; the discipline of LDS Church members, participants and leaders; and furthering the overall welfare of the LDS Church, its members, and participants. The President’s authority in the LDS Church’s affairs is absolute. He has the authority to dictate changes in the LDS Church’s policy, discipline, ecclesiastical doctrine, or anything else he so chooses. The acts of the President, in his capacity as head of the LDS Church, are the acts of Defendant Corporations.
  7.
  At all time relevant to this complaint, The Corporation of the Presiding Bishop of the
  Church of Jesus Christ of Latter-day Saints and the Corporation of the President of the Church of Jesus Christ of Latter-day Saints administer the LDS Church’s multilevel structure. The hierarchical structure is strict. The structure of the LDS Church pertinent to this case is as
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  follows: at the local level are “wards” (or in similar areas “branches”) (hereinafter “wards”). Wards consist of a geographical area administered by a bishop and two counselors. Together they comprise the governing “bishopric” and have comprehensive pastoral and administrative responsibility of the ward, including but not limited to primary responsibility for developmental programs involving the youth of the ward. Bishops are also obligated to oversee youth in the ward and youth activities. Bishops are also authorized to initiate serious Church disciplinary proceedings, including excommunication. The Bishop’s approval is necessary before a member of the ward can be baptized or ordained a priest.
  8.
  A cluster of wards is grouped into a “stake,” which is administered by a “Stake
  President,” and a Stake High Council. A Stake President is the presiding high priest of the stake and must oversee the welfare matters and records of the stake. A Stake High Council is a group of twelve men called to help oversee the work of the Stake. They are deemed High Councilors, who work directly under the direction of the stake president and help train and supervise Stake personnel or programs. The High Council also convenes as a disciplinary council in cases when serious misconduct or breach of church rules or teachings may affect someone’s church membership.
  9.
  Stakes are grouped into areas, which are administered by an Area President. All bishops, stake presidents, high councilors, and area presidents are agents of, exercise authority delegated by, and report to the LDS Church and the LDS President. The Wards, Stakes, and Areas of the LDS Church are instruments of Defendant Corporations and are not separate corporate entities.
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  10.
  Adherents of the faith who have been baptized into the LDS Church are known as members. Defendants have the power to limit or restrict the capacity in which any member serves or participates in the LDS Church and may place such conditions on a member as the LDS Church determines may be in its interests and the interests of its members, and prospective converts.
  11.
  Members of the LDS Church are instructed that the Bishops and Stake Presidents are “called by God” to their office, that Bishops and Stake Presidents are specially endowed with wisdom and understanding, and that the decisions of Bishops and Stake Presidents within the scope of their authority are guided by divine revelation. Members are encouraged to seek and comply with the advice of their Bishops and Stake Presidents on matters involving important decisions in their daily lives.
  12.
  Within the structure and doctrine of the LDS Church, member families and their homes are the central and most “basic unit” of the LDS Church. The LDS Church instructs that “[t]he work of salvation and exaltation is centered in the home and supported by the Church.” Occurrences within members’ families and activities within members’ homes are squarely within the purview of the LDS Church. As evidence of such, the LDS Church has published a “Family Guidebook” for its members. The leaders at every level, including stake presidents and bishops, are responsible for strengthening families, encouraging them to learn and pray within the home, and understanding their member’s home circumstances. The LDS Church’s
  role in members’ homes includes a priesthood program called “Home Teaching,” in which it Page 6 – COMPLAINT

  Case 6:25-cv-00222-MC Document 1 Filed 02/10/25 Page 7 of 21
  enlists agent-members of its priesthood to “visit the house of each member, exhorting them to pray vocally and in secret and attend to all family duties.” The LDS Church instructs Home Teacher that their duties include being “aware of the attitudes, the activities and interests, the problems, the employment, the health, the happiness, the plans and purposes, the physical, temporal, and spiritual needs and circumstances of everyone—of every child, every youth, and every adult in the homes and families who have been placed in our trust and care as a bearer of the priesthood, and as a representative of the bishop.” The doctrines of the LDS Church are clear that the Church is centered in the home and its leaders have a responsibility to care for and support the families of its members, including with problems in the home.
  The LDS Church’s Extensive Knowledge of the Problem of Child Abuse
  13.
  Since at least the 1990’s, LDS Church Defendants have been on notice of sustained and
  systemic problems of sexual abuse of children entrusted to its care. For example, within the last handful of years, thousands of claimants have alleged that they were sexually abused by LDS Church officials in LDS Church-run scouting troops. Over the same time period, many others have alleged abuse that occurred within the context of the LDS Church, but outside of the scouting context, including within religious services and programing and within the homes of LDS church members. The LDS Church has documented this knowledge, including in individual “Red Flags,” “annotations,” or other documents within or related to perpetrators’ LDS church membership files, in risk management files, in church discipline documents, in connection with the LDS Church Abuse Hotline (“Abuse Help Line” or “Hotline”) and elsewhere. This documentation comprised a body of specialized knowledge known to LDS Defendants regarding Page 7 – COMPLAINT

  Case 6:25-cv-00222-MC Document 1 Filed 02/10/25 Page 8 of 21
  the ongoing problem of sexual abuse of LDS youth. On information and belief from this body of specialized, Defendants knew: (a) the recidivistic nature of child sexual abusers; (b) the methods by which predatory child molesters accomplish their abuse of children (including how abusers groom and isolate victims to accomplish and continue abuse); (c) the common indications that abuse was occurring; and (d) the common escalation of abuse when intervention is not made. Based on this knowledge, on information and belief, Defendant was aware that children in special relationship with the LDS Church were in fact being sexually abused and knew that further sexual abuse would occur if agents of LDS Church Defendants did not properly respond to this known danger.
  14.
  LDS Church Defendants also have a history and pattern of failing to report and otherwise
  properly respond to child sexual abuse perpetrated by its members or reported to its leadership. This pattern has included, among other things, a policy or practice by LDS Church Defendants of handling information about suspected child sexual abuse internally rather than involving outside civil authorities. One of the LDS Church’s internal mechanisms for responding to information about suspected child sexual abuse has been through an internal, church-run abuse hotline to instruct and advise church leaders who received information indicating that abuse is occurring. On information and belief, one of LDS Church policies with regard to responding to suspected child sexual abuse has been to instruct that its agents receiving reports of abuse should “never advise a priesthood leader to report abuse,” but should instead refer to such individuals to the LDS Church’s attorneys for instruction. On information and belief, LDS Church has also maintained a policy requiring regular destruction of documentation created by its agents staffing its abuse hotline.
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  Plaintiff Julie Doe
  15.
  In approximately June of 2013, Julie Doe was placed in a foster care home with Jennifer
  Ford and Craig Ford, a married couple residing in Ridgefield, Washington with their two biological daughters. As a child in the foster care system, Julie Doe was extremely vulnerable. On information and belief, LDS Church Defendants knew that Julie Doe was placed in foster care with Jennifer Ford and Craig Ford and therefore knew that Julie Doe was particularly vulnerable. In 2014, the Fords adopted Julie Doe and, in 2015, they adopted from foster care another minor girl referred to herein as “Sheila Doe” (a pseudonym for a known victim of child sexual abuse not a party to this action).
  16.
  In 2015, the Ford family regularly attended an LDS Church ward in a stake near
  Ridgefield, Washington. There, Craig Ford regularly participated in Sacrament and Julie Doe participated in church youth activities, including serving as a counselor in a young women’s group.
  17.
  Around the end of December 2015, Craig Ford, then 31 years old, began sexually abusing
  Julie Doe when she was 15 years old. After the initial assault, Craig Ford continued his abuse of Julie Doe.
  18.
  Around late March or early April of 2016, Sheila Doe came into possession of more than a
  dozen letters containing sexual and romantic messages addressed to Julie Doe. Sheila Doe showed the letters to their adoptive mother Jennifer Ford (Craig Ford’s wife). After reviewing the letters,
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  Case 6:25-cv-00222-MC Document 1 Filed 02/10/25 Page 10 of 21
  Jennifer Ford recognized the handwriting as that of Craig Ford and confronted him about the sexual and romantic messages. Craig Ford admitted to writing the letters to Julie Doe. Based on the content of the letters Jennifer Ford concluded that Craig Ford was engaged in an inappropriate sexual relationship with the Plaintiff. This confrontation resulted in an argument that caused Sheila Doe to call the police. Clark County Sheriff’s Office responded to the call and filed a report. However, during this visit, Jennifer Ford did not disclose the sexual abuse of Plaintiff by Craig Ford to police. Jennifer Ford kept one or more of these letters in her possession after this confrontation.
  19.
  About a week or two later, in early April of 2016, all four children (including Plaintiff) were
  sent by Jennifer and Craig Ford to Montana to stay with relatives. During this time, Jennifer Ford searched Julie Doe’s room and found a sex toy. Jennifer Ford confronted Craig Ford who admitted he bought the sex toy and gave it to Julie Doe.
  20.
  While the children were in Montana, Jennifer Ford reported Craig Ford’s misconduct to an
  LDS Bishop and Stake President, Wade Pickett (hereinafter “Pickett”, “Bishop Pickett” or “Stake
  President Pickett”). Jennifer Ford showed Stake President Pickett the letter that Craig Ford had
  handwritten to Julie Doe, which Stake President Pickett read. That letter included statements
  calling Julie Doe “sexy”, telling her that he “enjoyed holding [Julie Doe] in his arms,” referring to
  “all the things [he] want[ed] to do to [her]” and encouraging Julie Doe to imagine how Craig
  Ford’s “arms wrap around [Julie Doe] and feel how our bodies just melt together”; and closing
  with Craig Ford expressing to Julie Doe: “I love you and want to be with you forever.” During this
  meeting, in addition to sharing the letter with Stake President Pickett, Jennifer Ford also expressed Page 10 – COMPLAINT

  Case 6:25-cv-00222-MC Document 1 Filed 02/10/25 Page 11 of 21
  that to Pickett that she suspected Craig Ford was having a sexual relationship with Julie Doe and, on information and belief, disclosed about and/or showed Pickett the sex toy Craig Ford bought for plaintiff.
  21.
  Jennifer Ford went to Stake President Pickett with the information set out in paragraphs 18
  through 20, above, at least in part, because of his role as a leader in and agent of the LDS Church (a Bishop and/or Stake President) and with the understanding that Stake President Pickett would know the appropriate course of action to take to respond to the suspected child sexual abuse of Julie Doe by Craig Ford. The information shared by Jennifer Ford with Pickett was material to Pickett’s agency duties to the LDS Church. The information learned by Pickett regarding Craig Ford’s abuse of Julie Doe was imputed to Defendants.
  22.
  Despite this information, Pickett did not take action to report the abuse to civil authorities,
  investigate, intervene, or otherwise prevent or protect against any further child sexual abuse of Julie Doe by Craig Ford. On information and belief, Pickett also did not advise Jennifer Ford to report the abuse. On information and belief, Pickett expressly or implicitly attributed responsibility (in whole or part) to Plaintiff for the sexual abuse.
  23.
  Within weeks of the initial report by Jennifer Ford to Stake President Pickett, Pickett
  learned that Craig Ford picked up Julie Doe from Montana and took her alone to Albany, Oregon where he remained with her. Pickett also learned at this time that Craig Ford and Jennifer Ford’s marriage was estranged and the two were separated. Still, the LDS Church took no action to report, investigate, intervene, or otherwise prevent or protect against further abuse of Julie Doe
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  by Craig Ford.
  24.
  Upon arriving in Albany, Oregon, the Defendants, already aware from previous reports
  and evidence that Craig Ford was sexually abusing Julie Doe, learned through its agents, that Craig Ford was cohabitating alone in an apartment with Julie Doe. Moreover, both Julie Doe and Craig Ford participated in church services and programming provided by the LDS Church Defendants in the Albany area. Agents of the Defendants also visited the apartment where Craig Ford was residing with Julie Doe. Through these interactions with and observations of Craig Ford and Julie Doe, Defendants learned through their agents that:
  • Julie Doe expressed to LDS Church leaders (agents of Defendants) that she had a difficult secret that she wanted to share with trusted church leaders but was having trouble bringing herself to disclose;
  • Craig Ford openly displayed risqué images of females and made references likening those images to Julie Doe;
  • Craig Ford engaged in unusual interactions with Julie Doe that were not like those of a caretaker and child; and
  • LDS Church leaders (including the Albany Ward Bishop) were concerned that something was amiss, within the household.
  On information and belief, based on this knowledge together with the earlier report to Stake President Pickett, the LDS Church was aware that Craig Ford was continuing his sexual abuse of Julie Doe.
  25.
  Starting in April 2016 and for months thereafter, Craig Ford proceeded to live alone
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  with Julie Doe in the Albany Area. Craig Ford sexually abused Julie Doe during this
  period on a.
  b. c. d. e.
  an almost daily basis, including:
  Taking Julie Doe’s clothes off;
  Groping Julie Doe’s breasts and genitals;
  Directing Julie Doe to perform oral copulation on Craig Ford; Subjecting Julie Doe to penile-vaginal penetration; and Subjecting Julie Doe to penile-anal penetration.
  26.
  information and belief, after LDS Church Defendants learned that Craig Ford was
  On
  sexually abusing Julie Doe, LDS Church Defendants expressly or implicitly attributed responsibility to Julie Doe (a minor), at least in part, for the sexual abuse she had suffered. On information and belief, by failing to properly intervene to stop the abuse or lend support to Julie Doe and while attributing responsibility to Julie Doe (at least in part) for the abuse, the LDS Church Defendants also knowingly allowed, permitted, and encouraged abuse of Julie Doe by Jennifer Ford in the form of mental cruelty to a child, including Jennifer Ford:
  • verbally harassing Plaintiff;
  • expressly blaming Plaintiff for the sexual abuse by Craig Ford;
  • repeatedly calling Plaintiff a “homewrecker”;
  • repeatedly calling Plaintiff a “slut”, a “whore” and similar slurs;
  • exclaiming to Plaintiff that she had caused injury to Craig Ford’s other children;
  • threatening to tell others (including Plaintiff’s biological mother) that Plaintiff had sexual contact with Craig Ford; and
  • encouraging Plaintiff to complete suicide. Page 13 – COMPLAINT

  Case 6:25-cv-00222-MC Document 1 Filed 02/10/25 Page 14 of 21
  27.
  In Fall of 2016, while Craig Ford was living with and sexually abusing Julie Doe in
  Albany, Oregon, Craig Ford’s youngest daughter gave a note with her classmate that read: “I wish my teacher knew that we think my dad had sex with sister[;] want to talk to you.” The classmate brought the note home to her mother, who immediately contacted the Vancouver Police Department. The Vancouver Police Department began an investigation in conjunction with the Washington Department of Social and Health Services (“DSHS”) Children’s Administration into the allegations contained in the note. During these investigations, Stake President Pickett was contacted and interviewed by DSHS. During that interview, Stake President Pickett acknowledged that he had been notified by Jennifer Ford that Craig Ford was sexually abusing Plaintiff, including that Jennifer Ford had shown him one or more incriminating letters that Craig Ford had written to Julie Doe which corroborated Ford’s abuse of Julie Doe.
  28.
  In 2018, Craig Ford was convicted on charges of incest and child molestation for the
  abuse of Sheila Doe in Superior Court of Washington, Clark County, Case No. 18-1-00824-7. In 2021, Craig Ford was convicted on charges of incest and rape for the abuse of Julie Doe in Circuit Court of Oregon, Linn County, Case No. 20CR44346. In 2022, Craig Ford was convicted on charges of incest and rape for the abuse of Julie Doe in Superior Court of Washington, Clark County, Case No. 20-1-01665-06. Craig Ford is currently serving a prison sentence.
  29.
  As a direct result of the sexual abuse, rape, and mental cruelty inflicted upon her, Plaintiff Page 14 – COMPLAINT

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  Julie Doe has suffered and will continue to suffer severe debilitating mental and emotional injury, including but not limited to pain and suffering, emotional trauma, disgrace, humiliation, shame, guilt, anxiety, stress, low self-esteem, depression, suicidal ideation, social isolation, embarrassment, avoidance, denial, anger, distrust of authority, nightmares, panic attacks, insomnia, and distrust of others. These injuries have caused and will continue to cause Plaintiff non-economic damages in the approximate amount of $20,000,000.00, the exact amount to be proven at trial.
  30.
  As a direct result of the sexual abuse, rape, and mental cruelty inflicted upon her,
  Plaintiff has incurred and will continue to incur lost earning capacity and costs for psychotherapy, psychological evaluations, psychiatric care, and/or other similar medical treatment. These injuries have caused and will continue to cause Plaintiff economic damages in the approximate amount of $5,000,000.00, the exact amount to be proven at trial.
  31.
  Plaintiff’s claims are timely pursuant to ORS 12.117.
  FIRST CLAIM FOR RELIEF
  NEGLIGENCE
  32.
  Plaintiff realleges and incorporates herein paragraphs 1 through 31.
  33.
  Defendants invited Plaintiff and all other members of the public to enter a special
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  relationship with the LDS Church, in part inviting Plaintiff to entrust herself into the care of the Church. Plaintiff did in fact enter into a special relationship with Defendants as a church member and/or participant in church services and programming. As a result of this special relationship, Defendants owed Plaintiff, a minor child, a special duty of care in addition to a duty of ordinary care to protect her from harm. Additionally, as a result of this special relationship, Plaintiff was a member of a class of individuals to be protected by proper warnings, interventions, reporting, child abuse prevention policies, trainings, education, and procedures regarding responding to known dangers of child sexual abuse. Such warnings, interventions, reporting, policies, trainings, education, and procedures would have protected Plaintiff from sexual abuse she suffered.
  34.
  Defendants, by and through their agents, knew of Craig Ford’s dangerous and abusive propensities, including towards Plaintiff specifically. Based on both its historical knowledge of other incidents of child sexual abuse and the specific knowledge it had about Craig Ford, it was foreseeable that if Defendants did not adequately respond to the danger Ford posed toward Plaintiff, Plaintiff (a child in a special relationship with Defendants) would be sexually abused by Craig Ford.
  35.
  Prior to the last incident of sexual abuse that Plaintiff suffered, Defendants knew that Craig Ford posed a danger of sexually abusing Plaintiff. On information and belief, Defendants knew that:
  a. Plaintiff’s adoptive mother, Jennifer Ford, reported that Craig Ford had a sexual relationship with Plaintiff;
  b. Craig Ford had written sexually suggestive letters to Plaintiff;
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  c. Craig Ford had purchased and provided a sex toy to Plaintiff;
  d. Plaintiff did not come home with the three other children from Montana;
  e. Craig Ford was not living in the family home in Ridgefield, but instead had
  separated from his wife and was living alone with Plaintiff near Albany,
  Oregon;
  f. Julie Doe expressed to LDS Church leaders (agents of Defendants) that she had
  a difficult secret that she wanted to share with trusted church leaders but was
  having trouble bringing herself to disclose;
  g. LDS Church leaders (agents of Defendants) observed in the apartment that
  Craig Ford openly displayed risqué images of females and made references
  likening those images to Julie Doe;
  h. LDS Church leaders (agents of Defendants) observed unusual interactions
  between Craig Ford and Julie Doe that were not like those of a caretaker and
  child; and,
  i. LDS Church leaders (including the Albany Ward Bishop) were concerned that
  something was unusual, amiss, or weird in the household.
  On information and belief, taking these observations and information together, LDS Church knew or reasonably should have known through its agents that Craig Ford had sexually abused Plaintiff and posed a danger of future sexual abuse of Julie Doe.
  36.
  On information and belief, prior to the last incident of child abuse in the form of mental
  injury or mental cruelty to Plaintiff inflicted by Jennifer Ford, Defendants knew or reasonably should have known that Jennifer Ford posed a danger of child abuse to Plaintiff. On information
  Page 17 – COMPLAINT

  Case 6:25-cv-00222-MC Document 1 Filed 02/10/25 Page 18 of 21
  and belief, Defendants knew that:
  a. Jennifer blamed Plaintiff for the sexual abuse that Craig Ford inflicted upon her;
  b. Jennifer had not contacted civil authorities to report the abuse of plaintiff by
  Craig Ford;
  c. Jennifer viewed Plaintiff as a “slut,” “whore,” and “homewrecker;”; and
  d. Jennifer posed a danger of inflicting upon intended to inflict mental injury upon
  Plaintiff for what Jennifer perceived as Plaintiff’s role in causing the child sexual abuse inflicted by Craig Ford
  37.
  Despite the knowledge set forth in paragraphs 1 through 36 above, Defendants breached its
  special duty of care to the minor Plaintiff by:
  a. Failing to effectively train church leaders (including Bishops, Stake Presidents and others) in how to properly respond to suspected child sexual abuse;
  b. Failing to educate Plaintiff and other LDS youth about the dangers of child sexual abuse (including that it is not the victim’s fault) and that such abuse will continue if the perpetrator maintains access to the victim;
  c. Failing to investigate reports of abuse of Plaintiff by Craig Ford;
  d. Failing to disclose to or concealing from law enforcement and other civil
  authorities’ information that indicated that Plaintiff was sexually abused by
  Craig Ford;
  e. Failing to disclose to or concealing from Plaintiff, law enforcement, or
  other civil authorities that Craig Ford posed a danger of further sexual
  abuse towards Plaintiff; Page 18 – COMPLAINT

  Case 6:25-cv-00222-MC Document 1 Filed 02/10/25 Page 19 of 21
  f. Failing to offer support or services to Plaintiff to ameliorate the effects of the abuse by Craig Ford;
  g. Failing to otherwise enforce LDS Church’s own stated policies and procedures for responding to suspected child sexual abuse; and
  h. Otherwise failing to reasonably respond to suspected child sexual abuse of minor church member or participant.
  Through these acts and omission, Defendants allowed, permitted and/or encouraged Plaintiff to continue to be endangered and abused by Craig Ford and Jennifer Ford and created the circumstance where Plaintiff was less likely to receive care, intervention, and/or treatment, thus exacerbating the harm done to Plaintiff.
  38.
  Defendants’ negligence, as detailed in paragraph 32 through 37 above, was unreasonable
  in light of the known threat posed to Plaintiff by Craig Ford and Jennifer Ford. In its negligence, Defendants knowingly allowed, permitted or encouraged child abuse pursuant to ORS 12.117. These acts and omissions were a direct and foreseeable cause of Plaintiff’s injuries and the subsequent damages suffered from the abuse committed by Craig Ford and Jennifer Ford. Any or all of Defendants’ acts and omissions described above caused some or all of Plaintiff’s abuse and damages.
  39.
  As a result of the aforementioned negligence, Plaintiff suffered the sexual abuse alleged
  at paragraphs 25 and 26 and the resulting damages alleged at paragraphs 29 through 30.
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  Case 6:25-cv-00222-MC Document 1 Filed 02/10/25 Page 20 of 21
  40.
  In light of Defendants’ knowledge of the danger posed by Craig Ford and Jennifer Ford,
  Defendants’ actions and omissions were undertaken with reckless and outrageous indifference to a highly unreasonable risk of harm and with a conscious indifference to the health, safety, and welfare of Plaintiff. Plaintiff is therefore entitled to punitive damages against Defendants in an amount to be determined by a jury.
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  Case 6:25-cv-00222-MC Document 1 Filed 02/10/25 Page 21 of 21
  PRAYER FOR RELIEF
  WHEREFORE, Plaintiff prays for judgment against Defendants as follows:
  1. Non-economic damage for Plaintiff in the amount of $20,000,000.00, the exact amount
  to be determined by the jury at the time of trial;
  2. Economic damage for Plaintiff in the amount of $5,000,000.00, the exact amount to be
  determined by the jury at the time of trial;
  3. Punitive damages against Defendants for an amount to be determined by the jury at trial;
  4. Plaintiff’s costs and disbursements incurred; and,
  5. For any other relief this Court deems just and equitable.

  DATED this 10th day of February 2025.
  Peter B. Janci, OSB No. 074249
  peter@crewjanci.com
  Kendall M. H. Spinella, OSB No. 214446
  kendall@crewjanci.com
  CREW JANCI LLP
  9755 SW Barnes Road., Ste. 430 Portland, OR 97225
  Tel: (503) 306-0224
  Of Attorneys for Plaintiff
  Page 21 – COMPLAINT