Parents who enrolled their children at Holy Angels Catholic School in Chicago had every reason to expect that the adults responsible for their education and religious instruction would look after their well-being. But allegations involving the former Holy Angels Parish in the Bronzeville neighborhood now raise disturbing questions about whether some of those trusted adults instead subjected children to sexual abuse.
The accusations involve several Catholic priests who worked within the Holy Angels community during different periods beginning in the late 1960s. Former students and other individuals have alleged that sexual misconduct occurred in connection with the parish, its school and activities involving children. The accusations have also prompted renewed examination of how the Archdiocese of Chicago responded to information about priests suspected of abusing minors.
Although some of the reported incidents occurred more than fifty years ago, the allegations remain relevant to survivors who may still be living with the consequences of childhood sexual abuse. They also raise an important legal question: whether the Church or other responsible institutions could have taken steps to prevent the alleged misconduct.
Sexner Injury Lawyers LLC represents individuals who have experienced sexual abuse involving clergy members, educators and other adults in positions of trust. Anyone who believes they were harmed at Holy Angels or another religious institution can speak confidentially with our Chicago sexual abuse attorneys by calling (312) 243-9922.
Allegations Involving Children at Holy Angels Parish and School
For many years, Holy Angels was closely associated with religious life and Catholic education on Chicago's South Side. Its church and school served families throughout the surrounding community, and the priests assigned there often occupied influential positions in the lives of parishioners.
That influence is important when considering the sexual abuse allegations. A priest might interact with children in several capacities: as a religious instructor, school administrator, counselor or leader of a youth activity. These relationships can involve substantial trust, particularly when parents have known and respected the same clergy members for many years.
Individuals who have come forward have accused clergy associated with Holy Angels of sexually abusing children during a period extending from approximately 1969 through 2002. Reported allegations concern misconduct involving students and children participating in parish-related programs, including scouting activities.
Some former students have described experiences involving more than one priest. The accusations therefore raise the possibility that alleged misconduct was not confined to an isolated encounter or a single individual.
The allegations are serious, keeping in mind that claims described in recent civil litigation have not all been established through judicial findings. Each accusation must be evaluated on its own evidence.
Catholic Priests Accused of Sexual Misconduct at Holy Angels
Four deceased priests have been identified in recent allegations concerning Holy Angels: Father George Clements, Father Paul Smith, Father John Calicott and Father Kenneth Brigham.
While the accusations involve the same parish community, the information publicly available about each priest differs considerably. Some allegations have only recently been asserted, while others were the subject of earlier investigations or official Church action.
Father George Clements and Father Paul Smith
George Clements became pastor of Holy Angels in 1969. He subsequently gained national recognition for his involvement in civil rights causes, community activities and programs benefiting children and families.
Paul Smith served as principal of Holy Angels School and worked closely with Clements during an important period in the school's history.
Both men have now been accused of sexually abusing children associated with Holy Angels. Among the recent allegations are accounts of misconduct allegedly involving the two priests together.
Because Clements and Smith held prominent leadership positions, the accusations raise questions about the ability of children to report inappropriate conduct involving adults who were widely respected within their community.
Concerns about Clements had become public years before the current allegations received widespread attention.
On August 8, 2019, the Archdiocese of Chicago issued a statement concerning an allegation that Clements sexually abused a minor in 1974. The Archdiocese explained that it had received the matter through the Chicago Police Department and that the accusation had also been reported to appropriate state and county authorities.
Cardinal Blase Cupich requested that Clements refrain from ministry while the allegation was investigated. Clements denied the accusation, which he characterized as unfounded. He died later that year.
The Archdiocese's original account of the matter remains available in its 2019 statement concerning Father Clements.
Smith died in 1996, long before the more recent accusations involving him became public. Those allegations have not been established by a court.
Father Kenneth Brigham
Kenneth Brigham is another former Holy Angels priest identified in the allegations of childhood sexual abuse.
The claims involving Brigham form part of the broader examination of alleged misconduct by clergy assigned to Holy Angels during earlier decades. Unlike the documented history concerning Father Calicott, the specific accusations involving Brigham have not been established through the same publicly available Illinois Attorney General findings.
It is therefore important to distinguish allegations made against Brigham from officially documented investigative conclusions concerning other priests.
Why Father John Calicott's History Raises Questions About Child Protection
One particularly significant part of the Holy Angels history involves Father John Calicott. Unlike some of the newer accusations, the Archdiocese's earlier handling of allegations against Calicott was examined in detail by the Illinois Attorney General.
In 1994, two individuals reported that Calicott had sexually abused them when they were minors during the 1970s. The Archdiocese's review board examined the accusations and determined that they were credible.
Nevertheless, Calicott later returned to active ministry as pastor of Holy Angels. His reinstatement occurred approximately eighteen months after the allegations were raised.
Conditions were attached to his return, including a restriction against being alone with a child unless another responsible adult was present. But the restrictions did not completely eliminate his opportunities to interact with minors.
Calicott continued serving in ministry until 2002, when he was removed. Additional allegations were subsequently reported to the Archdiocese.
These details are documented in the Illinois Attorney General's examination of the Archdiocese of Chicago's handling of clergy sexual abuse complaints.
Calicott's case illustrates a significant issue that can arise when an institution decides to supervise or restrict an accused individual rather than remove that person from an environment involving children.
Were the restrictions practical? Was someone responsible for enforcing them? Did the institution adequately consider the possibility of additional misconduct? And were parents given enough information to make informed decisions concerning their children's safety?
Those are important questions because a written restriction provides little protection if it cannot be reliably enforced.
Calicott died in 2024. His name appears in the Illinois Attorney General's publicly available records concerning clerics with substantiated child sexual abuse allegations.
What Responsibility Did Church Leadership Have to Protect Holy Angels Children?
Sexual abuse by a priest presents two separate areas of concern. The first involves the alleged conduct of the individual accused of harming a child. The second concerns the response of the organization that placed that individual in a position of authority.
When an institution receives information suggesting that an adult may pose a danger to children, its subsequent decisions can become critically important.
In a situation involving a parish or Catholic school, an investigation may need to determine who received an abuse complaint, whether the information was shared with decision-makers and what safeguards were established afterward.
For example, Church records might reveal that administrators discussed a priest's conduct, evaluated a complaint or considered changing his assignment. Other records could indicate whether restrictions were communicated to the individuals expected to enforce them.
Even when an institution adopts written safety procedures, investigators may need to examine whether those procedures were actually followed.
The Illinois Attorney General's investigation identified historical instances in which the Archdiocese of Chicago failed to carry out recommendations intended to prevent further abuse. The handling of Calicott's return to ministry at Holy Angels was among the examples discussed in that investigation.
Recent allegations have also raised concerns about whether children from the predominantly Black community served by Holy Angels received adequate attention when sexual misconduct was reported. Whether racial bias influenced any particular institutional decision is a separate factual question that would require supporting evidence.
These issues are relevant to determining whether negligent institutional conduct may have contributed to a child's injuries. However, a finding of civil liability requires proof of the elements of the particular legal claim.
Why Some Childhood Sexual Abuse Allegations Surface Many Years Later
When adults disclose abuse that allegedly happened during childhood, people sometimes wonder why they did not speak about it sooner. There are many reasons a child might remain silent, especially when the person accused of misconduct is a respected member of the clergy.
A young child may not fully understand the nature of inappropriate sexual conduct. Older children may recognize that something is wrong but feel unable to challenge an adult who has religious authority or substantial influence over their family.
Some children may fear that their parents will not believe an accusation against a trusted priest. Others may worry about creating conflict within their household, school or religious community.
In certain circumstances, an offender may attempt to discourage disclosure through threats, manipulation, special treatment or demands for secrecy. These behaviors can be associated with grooming, although the presence or absence of grooming must be evaluated in each individual case.
The consequences of childhood sexual abuse can also affect survivors differently. Some seek counseling early in life, while others may not discuss their experiences openly until adulthood. Emotional distress, difficulty with relationships, anxiety and other psychological effects may continue long after the abuse itself has ended.
These considerations help explain why a report made decades after an alleged incident should not be dismissed solely because of the passage of time. At the same time, the evidence supporting every individual allegation must still be carefully examined.
Can the Archdiocese Face a Civil Lawsuit Even If the Accused Priest Has Died?
Because the four priests identified in the recent Holy Angels allegations are deceased, survivors may question whether pursuing compensation is still possible.
The death of an alleged offender does not necessarily end every potential civil claim arising from the misconduct. In some circumstances, an organization may face a separate claim concerning its own acts or omissions.
For example, a lawsuit may examine whether an institution negligently retained a priest, permitted inappropriate access to children, failed to respond reasonably to warning signs or otherwise breached a legal duty to protect a child.
Establishing such a claim requires more than showing that sexual abuse allegedly occurred at a particular church or school. The available evidence must support the legal basis for holding the institution responsible.
A civil action is also different from a criminal prosecution. A criminal case is brought by government authorities and concerns criminal responsibility. A civil lawsuit may seek monetary compensation for injuries and other losses, using the legal standards applicable to civil proceedings.
Consequently, the absence of a criminal conviction does not automatically determine whether an injured person has a viable civil case.
Illinois Filing Deadlines for Sexual Abuse That Occurred Years Ago
Because the alleged Holy Angels misconduct dates back several decades, the applicable statute of limitations is an especially important consideration.
Illinois law has changed substantially in its treatment of civil claims arising from sexual abuse during childhood. Under the current version of 735 ILCS 5/13-202.2, a lawsuit seeking damages for childhood sexual abuse may generally be commenced at any time.
That language, however, does not mean every claim involving abuse from decades ago is automatically permitted.
Illinois law generally does not allow the elimination of a filing deadline to revive claims that were already legally barred under prior statutes. As a result, an attorney reviewing an older allegation must consider the historical law applicable to the particular claim.
Among the potentially relevant circumstances are the date of the alleged abuse, the survivor's age, when the injury and its relationship to the abuse were discovered, and whether any legally recognized reason affected the running of an earlier limitations period.
Someone who experienced sexual abuse many years ago should therefore obtain an individualized legal evaluation rather than assume either that the claim has expired or that it can unquestionably proceed.
How Can Allegations From Decades Earlier Be Investigated?
A substantial amount of time may have passed since the events described by former Holy Angels students and parishioners. Nevertheless, an investigation may uncover records and witnesses capable of providing useful information.
Evidence worth exploring could include:
- School and parish documentation: Enrollment information, staff assignments, historical parish publications and records identifying when particular priests worked with children.
- Church administrative records: Correspondence, personnel documents, prior complaints, internal reviews and decisions concerning clergy assignments or restrictions.
- People with firsthand knowledge: Former students, parents, employees and parish members who may remember relevant events or disclosures.
- Records relating to the survivor: Personal correspondence, contemporaneous notes, treatment records and other materials that may help establish the circumstances or effects of the alleged abuse.
The importance of each category depends upon the facts. Not every survivor will have documents from childhood, and the absence of such records does not automatically prevent an attorney from investigating a claim.
When more than one person reports misconduct involving the same individual, investigators may also examine whether the accounts reveal relevant similarities or identify additional sources of evidence.
Determining what an institution knew may require particular attention to documents created before the alleged abuse continued or before another child encountered the accused individual.
Our Firm Represents Survivors of Sexual Abuse by Archdiocese Priests
Sexner Injury Lawyers LLC has experience pursuing compensation for individuals who were sexually abused by clergy members.
In one such previous matter, our client reported that he had been subjected to prolonged sexual molestation by a priest working for the Archdiocese of Chicago. The abuse had occurred years before he contacted our office.
Our affiliated legal team investigated and pursued the matter, ultimately negotiating a $475,000 settlement involving sexual abuse by a priest.
The agreement provided financial compensation without requiring our client to describe the abuse in testimony at trial.
That result involved a different set of circumstances from the allegations concerning Holy Angels Parish. It nevertheless reflects the type of sensitive legal work our firm has undertaken on behalf of clergy abuse survivors.
Our practice also includes civil claims involving child abuse and institutional failures to protect children, including matters involving schools and organizations responsible for the welfare of minors.
Confidential Legal Assistance for Former Holy Angels Students and Parishioners
Individuals who experienced sexual abuse at Holy Angels Parish or its Catholic school may have questions about whether they can pursue legal action against the responsible parties. The same concerns may arise for survivors who were harmed at another Chicago church, school or religious organization.
Speaking with an attorney does not obligate someone to file a lawsuit. An initial consultation provides an opportunity to discuss the circumstances, identify potential legal issues and learn what an investigation might involve.
Sexner Injury Lawyers LLC understands that recounting childhood sexual abuse can be difficult, particularly when the alleged misconduct involved someone who held a position of religious authority. We approach these conversations with respect for each individual's privacy and personal circumstances.
If you or someone in your family experienced sexual abuse involving Holy Angels or another religious institution, contact Sexner Injury Lawyers LLC at (312) 243-9922 for a free, confidential consultation. Over $100,000,000 has been collected on behalf of our clients. Althoug every case is differrent, our legal team can evaluate the available information, explain the applicable law and discuss whether a civil claim may be possible.
