Combs v. Central Texas Annual Conference of the United Methodist Church’s Empirical Analysis
173 F.3d 343 · 1999
Citation profile
24 federal appellate · 5 district · 16 state decisions
How this case has been cited
Cited by 69 later decisions (2 by the Supreme Court) — most recently July 2021 · most notably Hosanna-Tabor Evangelical Lutheran Church & School v. Equal Employment Opportunity Commission (2012), Petruska v. Gannon University (2006)
24 federal appellate · 5 district · 16 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 42 U.S.C. § 2000B · 42 U.S.C. § 2000E (§ 701 of the Title VII of the Civil Rights Act of 1964)
Relies on Sherbert v. Verner · Employment Division Department of Human Resources of Oregon v. L Smith · City of Boerne v. Flores · Serbian Eastern Orthodox Diocese for United States and Canada v. Milivojevich · Presbyterian Church in US v. Mary Elizabeth Blue Hull Memorial Presbyterian Church
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 69 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]e cannot conceive how the federal judiciary could determine whether an employment decision concerning a minister was based on legitimate or illegitimate grounds without inserting ourselves into a realm where the Constitution forbids us to tread, the internal management of a church.”
9 later decisions quote this exact passage · from the majority“[T]he free exercise clause of the First Amendment protects the act of a decision rather than a motivation behind it.”
3 later decisions quote this exact passage · from the majority“[t]he relationship between an organized church and its ministers is its lifeblood. The minister is the chief instrument by which the church seeks to fulfill its purpose. Matters touching this relationship must necessarily be recognized as of prime ecclesiastical concern.... [Inquiry into a church’s decision regarding the] employment relationship existing between [ ] a church and its minister would result in an encroachment by the State into an area of religious freedom which it is forbidden to enter by the principles of the free exercise clause of the First Amendment.”
2 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.