Smith v. Allen’s Empirical Analysis
502 F.3d 1255 · 2007
Citation profile
30 federal appellate · 13 district · 2 state decisions
How this case has been cited
Cited by 106 later decisions (1 by the Supreme Court) — most recently November 2024 · most notably Sossamon v. Texas (2011), Sossamon v. Lone Star (2009)
30 federal appellate · 13 district · 2 state decisions
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 20 U.S.C. § 1681 (§ 901 of the Title IX of the Education Amendments of 1972) · 29 U.S.C. § 660 (§ 11 of the Occupational Safety and Health Act of 1970) · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act)) · 42 U.S.C. § 1997 (Civil Rights of Institutionalized Persons Act) · 42 U.S.C. § 2000C · 42 U.S.C. § 2000E (§ 701 of the Title VII of the Civil Rights Act of 1964)
Relies on Kentucky v. Graham · Carey v. Piphus · Sherbert v. Verner · Employment Division Department of Human Resources of Oregon v. L Smith · Pennhurst State School and Hospital v. Halderman
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 106 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In Franklin , the issue before the Court was what types of remedies were available in a private right of action for sex discrimination under Title IX of the Education Amendments of 1972, 20 U.S.C. § 1681 (“Title IX”). Although the statute was silent as to what remedies were available, the court stated that it was appropriate for a court to “presume the availability of all appropriate remedies unless Congress has expressly indicated otherwise.” 503 U.S. at 66 , 112 S.Ct. at 1032. Thus, absent any intent to the contrary reflected in the statute, the Court instructed that the presumption should be in favor of all available relief — both injunctive and monetary. Id. at 73, 112 S.Ct. at 1036.”
2 later decisions quote this exact passage · from the majority“In light of Franklin and its progeny, we agree that the use of the phrase “appropriate relief’ in section 3 of RLUIPA ... is broad enough to encompass the right to monetary damages in the event a plaintiff establishes a violation of the statute. Congress expressed no intent to the contrary within RLUIPA, even though it could have, by, for example, explicitly limiting the remedies [therein] to injunctive relief only. Instead, Congress used broad, general language in crafting the remedies section of RLUIPA, stating that a prevailing party could obtain “appropriate relief.” We assume that, when Congress acted, it was aware of Franklin’s presumption in favor of making all appropriate remedies available to the prevailing party. In light of that presumption, we conclude that, absent an intent to the contrary, the phrase “appropriate relief’ in RLUIPA encompasses monetary as well as injunctive relief.”
1 later decision quote this exact passage · from the majoritye.g. Dawson v. Burnett“If the word ‘substantial’ in the statutory phrase ‘substantial burden,’ 42 U.S.C. § 2000cc-l(a), is to retain any meaning, it must, at a minimum, be construed as requiring something more than solely the denial of a request that is sincere. An alternate approach ... would result in the word ‘substantial’ in § 20Q0cc-l(a) as being mere surplusage, since every governmental action denying a requested item to be used in religious observance would give rise to a prima facie RLUIPA claim.”
1 later decision 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.