Bryce’s Empirical Analysis
Citation profile
14 district · 29 state decisions
How this case has been cited
Cited by 78 later decisions (2 by the Supreme Court) — most recently March 2024 · most notably Hosanna-Tabor Evangelical Lutheran Church & School v. Equal Employment Opportunity Commission (2012), Hosanna-Tabor Evangelical Lutheran Church & School v. Equal Employment Opportunity Commission (2012)
14 district · 29 state decisions — followed in 16 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 Harlow v. Fitzgerald · Wisconsin v. Yoder · Employment Division Department of Human Resources of Oregon v. L Smith · Serbian Eastern Orthodox Diocese for United States and Canada v. Milivojevich · Watson v. Jones
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 78 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Plaintiff Smith contends that, unlike Bryce, she had no relationship with St. Aidan's and must be considered a third party who is not subject to internal church disciplinary procedures. This argument misses the mark. The church autonomy doctrine is rooted in protection of the First Amendment rights of the church to discuss church doctrine and policy freely. The applicability of the doctrine does not focus upon the relationship between the church and Rev. Smith. It focuses instead on the right of the church to engage freely in ecclesiastical discussions with members and non-members. Rev. Smith voluntarily attended the four meetings and voluntarily became part of St. Aidan's internal dialogue on homosexuality and Bryce's employment.”
2 later decisions quote this exact passage · from the dissent“as strong a duty to sit when there is no legitimate reason to recuse as he does to recuse when the law and facts require. The recusal statute should not be construed so broadly as to become presumptive or to require recusal based on unsubstantiated suggestions of personal bias or prejudice.”); Hinman v. Rogers, 831 F.2d 937, 939 (10th Cir.1987) (”
2 later decisions quote this exact passage · from the dissent“[t]he right to choose ministers is an important part of internal church governance and can be essential to the well-being of a church, “for perpetuation of a church’s existence may depend upon those whom it selects to preach its values, teach its message, and interpret its doctrines both to its own membership and to the world at large.””
2 later decisions quote this exact passage · from the dissent
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.