Elk Grove Unified School District v. Newdow’s Empirical Analysis
2004
Citation profile
363 federal appellate · 268 district · 96 state decisions
How this case has been cited
Cited by 1,505 later decisions (42 by the Supreme Court) — most recently June 2025 · most notably McDonald v. City of Chicago (2010), Cutter et al. v. Wilkinson Director Ohio Department of Rehabilitation and Correction (2005)
363 federal appellate · 268 district · 96 state decisions — followed in 23 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.
Appellate journey
reviewedNewdow v. US Congress (from Ninth Circuit Court of Appeals)
Relationships
Applies 10 U.S.C. § 502 · 28 U.S.C. § 1332 (Class Action Fairness Act of 2005) · 28 U.S.C. § 453 · 36 U.S.C. § 301 · 4 U.S.C. § 4 · 5 U.S.C. § 3331
Relies on Lujan v. Defenders of Wildlife · Warth v. Seldin · Younger v. Harris · Colorado River Water Conservation District v. United States · Allen v. Wright
Cited together with Lujan v. Defenders of Wildlife · Warth v. Seldin · Allen v. Wright · Valley Forge Christian College v. Americans United for Separation of Church and State, Inc. · Bell Atlantic Corp. v. Twombly
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 1,505 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the general prohibition on a litigant's raising another person's legal rights, the rule barring adjudication of generalized grievances more appropriately addressed in the representative branches, and the requirement that a plaintiff's complaint fall within the zone of interests protected by the law invoked.”
60 later decisions quote this exact passage · from the concurrence“In essence the question of standing is whether the litigant is entitled to have the court decide the merits of the dispute or of particular issues. The standing requirement is born partly of an idea, which is more than an intuition but less than a rigorous and explicit theory, about the constitutional and prudential limits to the powers of an unelected, unrepresentative judiciary in our kind of government.”
3 later decisions quote this exact passage · from the dissent“the general prohibition on a litigant’s raising another person’s legal rights”) and Worth v. Seldin, 422 U.S. 490, 500-01 , 95 S.Ct. 2197 , 45 L.Ed.2d 343 (1975) (recognizing that while standing”
3 later decisions quote this exact passage
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.