Missouri Governor Signs Law Making NDAs Unenforceable

A Texas bill is still waiting on the governor’s signature.

Missouri Governor Mike Kehoe has signed a bill into law voiding nondisclosure agreements (NDAs) in child sexual abuse cases.

Elizabeth Carlock Phillips holding a picture of her late brother Trey Carlock / Photo via social media

Trey’s Law, so titled for Trey Carlock who died by suicide after suffering sexual abuse at the hands of Peter Newman at Kanakuk Kamps, makes NDAs signed after August 28, 2025, unenforceable in childhood sexual abuse claims, the Springfield News-Leader reported.

The law was passed as an amendment to House Bill 737 in April.

Until now, Tennessee had been the only state to have passed a law — in 2018 — specifically prohibiting NDAs in civil child sexual abuse settlements, rendering them “void and unenforceable.”

Elizabeth Carlock Phillips, Trey’s sister, testified in favor of the Missouri bill. “It’s no exaggeration for me to claim this is a matter of life and death,” Phillips said. “When I say that my brother was silenced to his grave, I mean he was literally scared to death. He hesitated to tell his story even in confidential, therapeutic settings, for fear that Kanakuk would come after him again like they did an earlier John Doe.”

Nearly 30,000 people signed a petition asking Kanakuk to release sexual abuse victims from their NDAs. Phillips said Kanakuk first claimed they don’t use NDAs, then claimed it uses them only at the request of the victims, and finally admitted to using them but only because their insurance company requires them to do so.

According to TreysLaw.com, NDAs were created “to keep proprietary business information, such as trade secrets or sensitive client information, confidential.” However, they have since become a “standard practice in civil settlements related to child sexual abuse, trafficking and other crimes.”

The result may be that “bad actors are protected while survivors are forbidden to share their stories.”

Logan Yandell, another Kanakuk abuse survivor who entered a settlement with an NDA, filed a lawsuit alleging that his settlement was based on false and fraudulent representations by the Kanakuk defendants. His case was dismissed, but he will likely appeal the ruling.

Senate Bill 835 by Sen. Angela Paxton also passed in Texas in late May and is awaiting the signature of Gov. Greg Abbott. It makes an NDA “void and unenforceable as against the public policy of the state” if it “prohibits a party from disclosing an act of sexual abuse or facts related to an act of sexual abuse to any other person.”

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Cindy Clemishire, who made public allegations that Gateway Church founding pastor Robert Morris had sexually abused her starting when she was 12 years old, testified in favor of the Texas bill.

“Because I refused to sign an NDA, my abuser is finally being held accountable for the horrific crimes he committed against me as a child,” Clemishire said. She is now able to share her story and “be the voice for so many people who don’t have the courage to come forward.”

Morris is facing a five-count indictment in Oklahoma.

Joseph Cleveland has said he was groomed and molested by a man “working alongside” Chi Alpha, the college ministry of the Assemblies of God. During a committee hearing in Texas about Trey’s Law, Cleveland testified that he has “watched in horror” as the Assemblies of God used NDAs to “insulate organizational leadership” and “to hide.”

MinistryWatch has extensively reported about the sexual abuse scandal in Chi Alpha involving a man named Daniel Savala, who pleaded guilty to sexual abuse in Alaska but was still allowed to be involved with young men through Chi Alpha. He has since been indicted on charges of indecency with a child.

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