Carnes v. Smith’s Empirical Analysis
1976
Citation profile
3 federal appellate · 40 state decisions
How this case has been cited
Cited by 47 later decisions (2 by the Supreme Court) — most recently September 2017 · most notably Jones v. Wolf (1979), Minker v. Baltimore Annual Conference of United Methodist Church (1990)
3 federal appellate · 40 state decisions — followed in 12 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.
Relationships
Relies on Presbyterian Church in US v. Mary Elizabeth Blue Hull Memorial Presbyterian Church · Kedroff v. Saint Nicholas Cathedral of the Russian Orthodox Church in North America · Gonzalez v. Roman Catholic Archbishop · Maryland and Virginia Eldership of Churches of God v. Church of God at Sharpsburg Inc · Bornstein v. United States
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 47 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[n]o trust in favor of the general church may be implied under the general trust statutes ([cits.]).... However, [OCGA § 14-5-46] recognizes and validates deeds conveying land for church purposes according to the limitations set out in the deed and for use “according to the mode of church government or rules of discipline .. . .””
1 later decision quote this exact passage · from the majoritye.g. Kemp v. Neal“church property be held according to the terms of the church government,”
1 later decision quote this exact passage · from the majoritye.g. Jones v. Wolf
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.