Karen v. Treen’s Empirical Analysis
653 F.2d 897 · 1981
Citation profile
31 federal appellate · 1 district · 4 state decisions
How this case has been cited
Cited by 67 later decisions (1 by the Supreme Court) — most recently June 2025 · most notably Wallace v. Jaffree (1985), Holloman ex rel. Holloman v. Harland (2004)
31 federal appellate · 1 district · 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 Lemon v. Kurtzman · School District of Abington Township Pennsylvania v. Schempp J Murray III · Everson v. Board of Education · Walz v. Tax Comm'n of City of New York · Epperson v. Arkansas
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 67 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'The unmistakable message of the Supreme Court's teachings is that the state cannot employ a religious means to serve otherwise legitimate secular goals.' " Id. at 1286 (quoting Treen , 653 F.2d at 901 ). But this is not a school prayer case 16 and, under the Establishment Clause, "detail is key.”
7 later decisions quote this exact passage · from the majority“prayer is a primary religious activity in itself”
6 later decisions quote this exact passage · from the majority“[P]rayer is perhaps the quintessential religious practice for many of the world's faiths ... [it is] an address of entreaty, supplication, praise, or thanksgiving directed toward some sacred or divine spirit, being or object.”
5 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.