Bowen v. Roy’s Empirical Analysis
1986
Citation profile
241 federal appellate · 65 district · 142 state decisions
How this case has been cited
Cited by 726 later decisions (31 by the Supreme Court) — most recently November 2025 · most notably Employment Division Department of Human Resources of Oregon v. L Smith (1990), Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah (1993)
241 federal appellate · 65 district · 142 state decisions — followed in 25 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
Applies 42 U.S.C. § 1996 (American Indian Religious Freedom Act) · 42 U.S.C. § 2000D · 42 U.S.C. § 602 (§ 402 of the Social Security Act of 1935) · 7 U.S.C. § 2011 (Charitable Assistance and Food Bank Act of 1987) · 7 U.S.C. § 2025
Relies on Goldberg v. Kelly · Townsend v. Sain · McGowan v. State of Maryland Gallagher · Cantwell v. State of Connecticut · Shapiro v. Thompson
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 726 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he Free Exercise Clause simply cannot be understood to require the Government to conduct its own internal affairs in ways that comport with the religious beliefs of particular citizens.”
24 later decisions quote this exact passage · from the majority“Absent proof of an intent to discriminate against particular religious beliefs or against religion in general, the Government meets its burden when it demonstrates that a challenged requirement for governmental benefits, neutral and uniform in its application, is a reasonable means of promoting a legitimate public interest.”
10 later decisions quote this exact passage · from the concurrence“a state creates such a mechanism, its refusal to extend an exemption to an instance of religious hardship suggests a discriminatory intent,”
6 later decisions quote this exact passage · from the concurrence
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.