Watson v. Jones’s Empirical Analysis
80 U.S. 679 · 1871
Citation profile
164 federal appellate · 63 district · 728 state decisions
How this case has been cited
Cited by 1,199 later decisions (56 by the Supreme Court) — most recently June 2025 · most notably School District of Abington Township Pennsylvania v. Schempp J Murray III (1963), Everson v. Board of Education (1947)
164 federal appellate · 63 district · 728 state decisions — followed in 47 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.
Relationships
Relies on Hayden v. The Oriental Mills · Miller v. Gable
Cited together with Serbian Eastern Orthodox Diocese for United States and Canada v. Milivojevich · Kedroff v. Saint Nicholas Cathedral of the Russian Orthodox Church in North America · Presbyterian Church in US v. Mary Elizabeth Blue Hull Memorial Presbyterian Church · Jones v. Wolf · Gonzalez v. Roman Catholic Archbishop
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 1,199 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The law knows no heresy, and is committed to the support of no dogma, the establishment of no sect.”
122 later decisions quote this exact passage · from the majority“the rights of such bodies to the use of the property must be determined by the ordinary principles which govern voluntary associations. If the principle of government in such cases is that the majority rules, then the numerical majority of members must control the right to the use of the property. If there be within the congregation officers in whom are vested the powers of such control, then those who adhere to the acknowledged organism by which the body is governed are entitled to the use of the property.”
17 later decisions quote this exact passage · from the majority““The questions which have come before the civil courts concerning the rights to property held by ecclesiastical bodies, may, so far as we have been able to examine them, be profitably classified under three general heads, which of course do not include cases governed by considerations applicable to a church established and supported by law as the religion of the state. “1. The first of these is when the property which is the subject of controversy has been, by the deed or will of the donor, or other instrument by which the property is held, by the express terms of the instrument devoted to the teaching, support, or spread of some specific form of religious doctrine or belief. “2. The second is when the property is held by a religious congregation which, by the nature of its organization, is strictly independent of other ecclesiastical associations, and so far as church government is concerned, owes no fealty or obligation to any higher authority. “3. The third is where the religious congregation or ecclesiastical body holding the property is but a subordinate member of some general church organization in which there are superior ecclesiastical tribunals with a general and ultimate power of control more or less complete, in some supreme judicatory over the whole membership of that general organization.””
15 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.