Employment Division Department of Human Resources of Oregon v. L Smith’s Empirical Analysis
1990
Citation profile
1,152 federal appellate · 432 district · 827 state decisions
How this case has been cited
Cited by 4,039 later decisions (101 by the Supreme Court) — most recently June 2026 · most notably Planned Parenthood of Southeastern Pennsylvania v. P Casey P Casey (1992), Lucas v. South Carolina Coastal Council (1992)
1,152 federal appellate · 432 district · 827 state decisions — followed in 43 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 21 U.S.C. § 812 (§ 202 of the Controlled Substances Act) · 42 U.S.C. § 1996 (American Indian Religious Freedom Act)
Relies on United States v. O'Brien · Washington v. Davis · Cantwell v. State of Connecticut · Wisconsin v. Yoder · Sherbert v. Verner
Cited together with Sherbert v. Verner · Wisconsin v. Yoder · Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah · City of Boerne v. Flores · Thomas v. Review Board of the Indiana Employment Security Division
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 4,039 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“cannot depend on measuring the effects of a governmental action on a religious objector's spiritual development.”
79 later decisions quote this exact passage · from the concurrence“The free exercise of religion means, first and foremost, the right to believe and profess whatever religious doctrine one desires.”
65 later decisions quote this exact passage · from the majority“the right of free exercise does not relieve an individual of the obligation to comply with a valid and neutral law of general applicability on the ground that the law proscribes (or prescribes) conduct that his religion prescribes (or proscribes).”
61 later decisions quote this exact passage · from the majority
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.