CHICAGO (IL)
Hart McLaughlin & Eldridge [Chicago IL]
October 15, 2026
[Note: The text below is an excerpt. Please see the full text of this significant complaint, which includes photographs and documents.]
1. This action is brought against the Archdiocese of Chicago on behalf of one of the likely hundreds of victims of child sexual abuse committed by priests assigned to the Holy Angels Parish (“Holy Angels,” the “Parish”) between 1969 and 2002, particularly Father George Clements (“Fr. George Clements,” “Fr. Clements,” “George Clements,” or “Clements”), Father Paul Smith (“Fr. Paul Smith,” “Fr. Smith,” “Paul Smith,” or “Smith”), Father John Calicott (“Fr. John Calicott,” “Fr. Calicott,” “John Calicott,” or “Calicott”), and Father Kenneth Brigham (“Fr. Kenneth Brigham,” “Fr. Brigham,” “Kenneth Brigham,” or “Brigham”).
2. In spite of the Archdiocese of Chicago’s efforts to conceal it, substantial evidence overwhelmingly proves that one of the most famous and controversial priests in its history, George Clements, was the spearhead of a decades-long surge of relentless child molestation by a small, close-knit community of Archdiocesan priests assigned to several predominantly Black, inner-city parishes – with Holy Angels being its epicenter.
3. The uniquely appalling and enduring tragedy manifested at Holy Angels was entirely predicated on the Archdiocese of Chicago’s deliberate and unspoken abdication of virtually all responsibility to the Parish, its parishioners, and the students at its Catholic grammar school (“Holy Angels School,” the “School”) for an entire generation.
4. As a consequence of that deliberate abdication of responsibility the Archdiocese of Chicago knowingly permitted Fr. George Clements and Fr. Paul Smith to take unbridled control of Holy Angels and go completely rogue, with the two of them leveraging their status as Archdiocesan priests, positions of unmatched authority, and Parish assets to perpetuate a child exploitation enterprise lasting more than 20 consecutive years.
5. Despite its willful blindness, the Archdiocese of Chicago nonetheless became aware of substantial amounts of Fr. Clements’s and Fr. Smith’s profound misconduct as well as conspicuous red flags and hazards that the Archdiocese had a duty to address, but never did.
6. In failing to do so, the Archdiocese of Chicago wantonly disregarded the safety, wellbeing, and innocence of the overwhelmingly poor, Black boys who studied or prayed at Holy Angels and were sexually molested by Fr. Clements or Fr. Smith on an almost daily basis.