Lemon v. Kurtzman’s Empirical Analysis
1971
Citation profile
1,749 federal appellate · 615 district · 1,080 state decisions
How this case has been cited
Cited by 5,883 later decisions (192 by the Supreme Court) — most recently June 2025 · most notably Buckley v. Valeo (1976), Valley Forge Christian College v. Americans United for Separation of Church and State, Inc. (1982)
1,749 federal appellate · 615 district · 1,080 state decisions — followed in 46 states
Later decisions citing this case, by decade. A case is still cited after being overruled — to note the reversal, distinguish it, or in dissent. 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 20 U.S.C. § 711 · 28 U.S.C. § 2281
Relies on Brown et al. v. Board of Education of Topeka et al. · Flast v. Cohen · McGowan v. State of Maryland Gallagher · Meyer v. State of Nebraska
Cited together with Lynch v. Donnelly · School District of Abington Township Pennsylvania v. Schempp J Murray III · Everson v. Board of Education · County of Allegheny v. American Civil Liberties Union · Walz v. Tax Comm'n of City of New York
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 5,883 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“an excessive government entanglement with religion.”
419 later decisions quote this exact passage · from the majority“excessive entanglement between government and religion.”
10 later decisions quote this exact passage“'the secular education those schools provide goes hand in hand with the religious mission that is the only reason for the schools' existence. Within the institution, the two are inextricably intertwined.'”
4 later decisions quote this exact passage · from the concurrencee.g. Albert C. Walker Roberta M. Walker John C. Soso Jacklyn C. Soso Margaret Smith Alyce Crosdale Betty Sands v. San Francisco Unified School District, and United States Department of Education Lamar Alexander, in His Official Capacity as Secretary of Education, Defendants-Intervenors-Appellants. Albert C. Walker Roberta M. Walker John C. Soso Jacklyn C. Soso Margaret Smith Alyce Crosdale Betty Sands v. Board of Education of the San Francisco Unified School District, City and County of San Francisco, State of California Ramon Cortines, Superintendent of Schools, San Francisco Unified School District San Francisco Unified School District, Albert C. Walker Roberta M. Walker John C. Soso Jacklyn C. Soso Margaret Smith Alyce Crosdale Betty Sands v. San Francisco Unified School District, City and County of San Francisco, State of California, and Deborah Martin Jacob Perea Barbara Perea, Defendants-Intervenors-Appellants. Albert C. Walker Roberta M. Walker John C. Soso Jacklyn C. Soso Margaret Smith Alyce Crosdale Betty Sands v. William Honig, as California Superintendent of Public Instruction California Department of Education California State Board of Education, and San Francisco Unified School District, Albert C. Walker Roberta M. Walker John C. Soso Jacklyn C. Soso Margaret Smith Alyce Crosdale Betty Sands v. Board of Education of the San Francisco Unified School District San Francisco Unified School District, City and County of San Francisco, State of California Ramon Cortines, Superintendent of Schools, San Francisco Unified School District, United States Department of Education Deborah Martin Lamar Alexander, in His Official Capacity as Secretary of Education Jacob Perea Barbara Perea, Defendants-Intervenors-Appellees · 461 F. Supp. 1123 - COMMITTEE FOR PUBLIC ED., ETC. v. Levitt
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.