Bradfield v. Roberts’s Empirical Analysis
175 U.S. 291 · 1899
Citation profile
61 federal appellate · 22 district · 60 state decisions
How this case has been cited
Cited by 265 later decisions (44 by the Supreme Court) — most recently October 2018 · most notably Valley Forge Christian College v. Americans United for Separation of Church and State, Inc. (1982), Flast v. Cohen (1968)
61 federal appellate · 22 district · 60 state decisions — followed in 18 states
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.
Appellate journey
reviewedthe decision below (from District of Columbia Circuit Court of Appeals)
Relationships
Relies on 12 App. D.C. 453 - Roberts v. Bradfield
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 265 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he Court refused to hold that the mere fact that the hospital was “conducted under the auspices of the Roman Catholic Church” was sufficient to alter the purely secular legal character of the corporation, particularly in the absence of any allegation that the hospital discriminated on the basis of religion or operated in any way inconsistent with its secular charter.”
3 later decisions quote this exact passage · from the majority“Nothing is said about religion or about the religious faith of the incorporators of this institution in the act of incorporation____ The facts above stated do not in the least change the legal character of the hospital, or make a religious corporation out of a purely secular one as constituted by the law of its being---- That the influence of any particular church may be powerful over the members of a nonseetarian and secular corporation, incorporated for a certain defined purpose and with clearly stated powers, is surely not sufficient to convert such a corporation into a religious or sectarian body____ There is no allegation that its hospital work is confined to members of that church or that in its management the hospital has been conducted so as to violate its charter in the smallest degree____ The charter itself does not limit the exercise of its corporate powers to the members of any particular religious denomination, but, on the contrary, those powers are to be exercised in favor of anyone seeking the ministrations of that kind of an institution____ Its property is to be acquired in its own name and for its own purposes; that property and its business are to be managed in its own way, subject to no visitation, supervision, or control by any ecclesiastical authority whatever, but only to that of the government which created it.”
2 later decisions quote this exact passage · from the majority“Nothing is said about religion or about the religious faith of the incorporators of this institution in the act of incorporation.... Whether the individuals who compose the corporation under its charter happen to be all Roman Catholics, or all Methodists, or Presbyterians, or Unitarians, or members of any other religious organization, or of no organization at all, is of not the slightest consequence with reference to the law of its incorporation, nor can the individual beliefs upon religious matters of the various incorporators be inquired into.”
1 later decision 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.