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← 187 ALA 273 - Barton v. Fitzpatrick

Barton v. Fitzpatrick’s Empirical Analysis

1914

Citation profile

38
cited by 38 later decisions
6
states following
July 2017
most recently cited

2 federal appellate · 36 state decisions

How this case has been cited

Cited by 38 later decisions — most recently July 2017 · most notably Williams v. Jones (1952), 186 So. 2d 102 - In Re Galilee Baptist Church (1966)

2 federal appellate · 36 state decisions

6019141920193019401950196019701980199020002010decided

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

Relies on Gewin v. Mt. Pilgrim Baptist Church · Stewart v. White · Morris Street Baptist Church v. Dart · Morgan v. Gabard · State, ex rel. McNeill v. Bibb Street 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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “"The rule of the common law seems to be that, where a body is composed of an indefinite number of persons, a quorum, for the purposes of elections and voting upon other questions, which require the sanction of the members, consists of those who assemble at any meeting regularly called and warned, although such number may be a minority of the whole, in which case a majority of those who assemble may elect, unless there is a different rule established by statute or valid by-law."”
    2 later decisions quote this exact passage
  2. “"a pure democracy, and, apart from some general regulations which have been accepted as a sort of covenant by all the churches of that denomination, each church is a law unto itself in the management of its own affairs. Its organization is congregational, and each church must of necessity be governed by laws which inhere in that form of government."”
    2 later decisions quote this exact passage
  3. “The pastor of a church in his pastoral office performs a spiritual function. Spiritualities are beyond the reach of the temporal courts. It follows that a church which has employed a pastor, though the employment be for a fixed term and at a fixed salary, may at any time , so far as the civil courts are concerned, depose him from his spiritual office, subject only to inquiry by the courts as to whether the church, or its appointed tribunal, has proceeded according to the law of the church; nor can the payment of his salary, though in arrear, be made a condition precedent to his deposition. And in the case of a church organized on the congregational plan the inquiry is limited to the determination whether in fact the church has acted as a congregation. . . . [Emphasis added.]”
    1 later decision quote this exact passage

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.