63 Cal. App. 209 - Frohliger v. Richardson’s Empirical Analysis
1923
Citation profile
9 federal appellate · 23 state decisions
How this case has been cited
Cited by 48 later decisions — most recently September 2018 · most notably 22 Cal. 3d 792 - Fox v. City of Los Angeles (1978), 12 Cal. 3d 593 - California Educational Facilities Authority v. Priest (1974)
9 federal appellate · 23 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 Stevenson v. Colgan · Conlin v. Board of Supervisors · Daggett v. Colgan · Bourn v. Hart · Rankin v. Colgan
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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We concede that the California missions are of historical and educational interest from a cultural and literary standpoint, but they approach no such classification as would make them the basis of the state’s bounty or the subject of legislative appropriation in the guise of public interest, public good, or public welfare. We have endeavored to make it clear that we are in sympathy with the meritorious movement having for its object the restoration and preservation of the missions, but no matter how praiseworthy we may believe such efforts to be, we must say that, in our opinion, the state constitution forbids that such work be done at the expense of the taxpayers. We believe that the act of the legislature under consideration is in manifest violation of ... the state constitution_”
2 later decisions quote this exact passage“Those who argue that the amount of taxpayer funds expended to light the cross is so minimal as to be beneath this court’s notice, overlook two important considerations. First, article XVI, section 5 admits of no de minimis exception. The language is explicit: No “city ... shall ever ... pay from any public fund whatever, or grant anything to or in aid of any religious sect....” Secondly, the prohibitions of article XVI, section 5 would come into play even if no funds were expended. The ban is on aid to religion in any form.”
1 later decision quote this exact passagee.g. Hewitt v. Joyner
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.