Doe v. Irwin’s Empirical Analysis
615 F.2d 1162 · 1980
Citation profile
5 federal appellate · 4 state decisions
How this case has been cited
Cited by 16 later decisions — most recently February 2025
5 federal appellate · 4 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
Relies on Roe v. Wade · Griswold v. State of Connecticut · Meyer v. State of Nebraska · Wisconsin v. Yoder · Pierce v. Society of the Sisters of the Holy Names of Jesus and Mary Same
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In each of the Supreme Court cases the state was either requiring or prohibiting some activity. In Meyer v. Nebraska, [ 262 U.S. 390 , 43 S.Ct. 625 ,] the state forbade the teaching of foreign languages to pupils who had not passed the eighth grade. The Court held the statute not reasonably related to any end within the competency of the state and violative of parents’ Fourteenth Amendment right to liberty. In Pierce v. Society of Sisters, [ 268 U.S. 510 , 45 S.Ct. 571 ,] the statute required all children between the ages of 8 and 16 to attend public schools. The Court found that the law unreasonably interfered with the liberty interest of parents to direct the upbringing and education of their chil dren, including the right to send them to accredited private schools. Again in Wisconsin v. Yoder, [ 406 U.S. 205 , 92 S.Ct. 1526 ,] the law in question made school attendance compulsory. The Court held that Amish parents’ First Amendment rights to the free exercise of their religion were infringed by the attendance requirement. In Prince v. Massachusetts, [ 321 U.S. 158 , 64 S.Ct. 438 ,] child labor laws were construed to prohibit street sales of religious tracts by children. In that case the Court upheld the conviction of a parent who contended that these laws unreasonably interfered with her right of free exercise of religion and her parental rights. In so holding, the Court determined that a state’s “authority is not nullified merely because the parent grounds his claim to con”
2 later decisions quote this exact passage · from the concurrence“Though the state has somewhat broader authority to regulate the conduct of children than that of adults, minors do possess a constitutionally protected right of privacy.”
2 later decisions quote this exact passage · from the majority“free to exercise their traditional care, custody and control over their unemancipated children.”
2 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.