An editorial from the LATimes, which has not distinguished itself by aggresive reporting in this area

When it comes to investigating priests accused of molesting children, Los Angeles Cardinal Roger M. Mahony is more aggressive than any other bishop in the country. At shielding priests, that is, not at safeguarding children from sexual abuse.

For more than a year and a half, Mahony has refused to release communications between him and his priests sought by prosecutors, lawyers for alleged victims and the public. As The Times reported Sunday, his chief lawyer has even invented a name for this stonewalling — “formation privilege” — and argues that to force the cardinal to breach confidentiality would violate state laws that shield communications between a priest and a penitent as well as state and federal guarantees of religious freedom.