"People v. Phillips is a right of the Church to its rituals."
The Irish Government enacted legislation that removed the priest-penitent confidentiality privilege. The Australian Royal Commission into Institutional Responses to Child Sexual Abuse has recommended the Australian Federal and State Governments to enact legislation to do the same. The Commission found that pedophile priests that went to confession and obtained absolution were more likely to keep sexually assaulting children. It is only a matter of time until similar legislation is enacted in the United States.
http://www.childabuseroyalcommission.gov.au/media-centre/media-releases/2017-08/report-on-criminal-justice-released