The first amendment gives you priest penitent. I am familiar with the therapy obligation to report danger to another. The quote above was from wikipedia and quoted the relevant case law in People v. Phillips. Therapy is not religion and confession is not therapy.. Frankly, changing the rules won't do that much much for the victims if the confessor directs the penitent to turn himself in. If you want to change the rules on confession in the Church, fight for a ruling that says that the Vatican is liable for the actions of bishops and priests on this issue. That is likely easier than getting this Court change first amendment law in this instance.