The Rev. O. Lloyd Hutchison’s Empirical Analysis

Citation profile

1 federal appellate · 5 district · 46 state decisions

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 66 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[A] minister's employment relationship with his church implicates `internal church discipline, faith, and organization, all of which are governed by ecclesiastical rule, custom, and law.'”

   7 later decisions quote this exact passage · from the majority
   e.g. Hudson Presbyterian Church v. Eastminster Presby., 24279 (2-4-2009) · Tharp v. Hillcrest Baptist Church of Columbus

2. ““Appellant is really seeking civil court review of subjective judgments made by religious officials and bodies that he had become ‘unappointable’ due to recurring problems in his relationships with local congregations. This Court cannot constitutionally intervene in such a dispute.””

   2 later decisions quote this exact passage · from the majority
   e.g. Patton v. Jones · 111 Md. App. 616 - Downs v. ROMAN CATH. ARCHBISHOP OF BALT.

3. “Thus, although Watson had left civil courts no role to play in reviewing ecclesiastical decisions during the course of resolving church property disputes, Gonzalez first adverted to the possibility of “marginal civil court review” in cases challenging decisions of ecclesiastical tribunals as products of “fraud, collusion, or arbitrariness.” However, since there was “not even a suggestion that the Archbishop exercised his authority in making the chaplaincy decision arbitrarily, the suggested “fraud, collusion, or arbitrariness” exception to the Watson rule was dictum only. And although references to the suggested exception appear in opinions in cases decided since the Watson rule has been held to be mandated by the First Amendment, no decision of this Court has given concrete content to or applied the “exception.” . . . We have concluded that, whether or not there is room for “marginal civil court review” under the narrow rubrics of “fraud” or “collusion” when church tribunals act in bad faith for secular purposes, no “arbitrariness” exception - in the sense of an inquiry whether the decisions of the highest ecclesiastical tribunal of a hierarchical church complied with church laws and regulations - is consistent with the constitutional mandate that civil courts are bound to accept the decisions of the highest judicatories of a religious organization of hierarchical polity on matters of discipline, faith, internal organization, or ecclesiastical rule, custom, or law.”

   1 later decision quote this exact passage · from the majority
   e.g. Denny v. Prince