Trivial Pursuit

paul-finkelman at utulsa.edu paul-finkelman at utulsa.edu
Sun Aug 13 16:05:09 PDT 2006


Would anyone add Pierce v. SOciety of Sisters or Meyer v. Neb. to this list?

Paul Finkelman
pfink at albanylaw.edu

Quoting Douglas Laycock <DLaycock at law.utexas.edu>:

> There are more than twenty important cases.  I don't doubt the
> importance of anything on Marty's list.  But for the most
> part, I don't see what to displace to add them.
>  
> Probably I thought too much about the Lemon test and neglected
> the one clear rule that Lemon does still stand for:  no
> government cash can go directly to a religious school.  Put
> that way, Lemon probably moves up onto the list and some other
> case drops out.
>  
> The other cases in the long line from Lemon to Mitchell take a
> long time to teach if you still teach them, but the sheer
> number of them and their tendency to focus on detail makes it
> hard to single out any one as especially important.  I suppose
> Mitchell and Agostini would be the top picks in that line
> after Lemon.  The capacity to voucherize the money greatly
> makes the whole line largely a matter of program design with
> respect to schools, but the litigation over faith-based social
> shows that they still have some life.  Still, for a mix of
> these reasons, I'm not inclined to give you any more than
> Lemon in that sequence.
>  
> I teach this line of cases pretty quickly, and tell students
> from the get to that they are not responsible for the
> details.
>  
> Douglas Laycock
> Alice McKean Young Regents Chair in Law
> The University of Texas at Austin
>  
> Mailing Address:
> Prof. Douglas Laycock
> University of Michigan Law School
> 625 S. State St.
> Ann Arbor, MI  48109
> 
> ________________________________
> 
> From: marty.lederman at comcast.net
> [mailto:marty.lederman at comcast.net]
> Sent: Sun 8/13/2006 1:31 PM
> To: Law & Religion issues for Law Academics;
> religionlaw at lists.ucla.edu
> Cc: Douglas Laycock
> Subject: Re: Trivial Pursuit
> 
> 
> A fine list, to be sure, Doug.  But there are a couple of very
> conspicuous omissions that I'm sure were intentional and as to
> which I'd love to know your reasoning.
>  
> The most important category, of course, is the "direct
> funding" cases, from Lemon (or even Allen) through Mitchell v.
> Helms, including, e.g., Tilton, Roemer, Hunt, Levitt, Nyquist,
> Wolman, Aguilar, Agostini, Kendrick, et al.  These cases
> dominated discussion (and SCOTUS litigation) in this area for
> several decades, and they still occupy a large part of most
> courses on religious liberty, mine included.  Forget the Lemon
> "test":  The Lemon *holding*, that direct aid may not be used
> for religious purposes, is hugely important, and still hotly
> contested (see the various opinions in Mitchell, and the
> debates over the faith-based initiative).  It's much more
> important, in my view, than the "access" cases in the Widmar
> line, several of which you list.
>  
> You also omit the permissive accommodation cases -- Zorach,
> Amos, Thornton, Texas Monthly, etc. -- perhaps thinking that
> Cutter is sufficient.  But I think this, too, is an incredibly
> complex and contested area, and the handful of cases thus are
> of great significance.
>  
> Relatedly, there are the cases involving nominally statutory
> questions of what counts as "religion" for puposes of
> accommodation -- e.g., Welsh, Gillette and Seeger.  I think
> Kent Greenawalt is right that these issues, rarely litigated
> today (but see the fascinating Becker opinion in Malnak v.
> Yogi), are important foundational issues.  See also Ballard,
> on the basic question of how the state can or cannot evaluate
> religious truth.
>  
> 
> 	-------------- Original message -------------- 
> 	From: "Douglas Laycock" <DLaycock at law.utexas.edu> 
> 	
> 	Here is a potential source of endless pointless debate.  Two
> professors are working on a mathematical model to rank the
> importance of Supreme Court decisions.  They want to test
> their model against the subjective assessments of con law
> professors.  So they asked me and I assume many others to rank
> order the twenty most important cases on a topic I knew well. 
> My caveats, and my list, are below.  
> 	 
> 	Douglas Laycock
> 	Alice McKean Young Regents Chair in Law
> 	The University of Texas at Austin
> 	 
> 	Mailing Address:
> 	Prof. Douglas Laycock
> 	University of Michigan Law School
> 	625 S. State St.
> 	Ann Arbor, MI  48109
> 
> 	[addressee deleted]
> 	 
> 	 I am at last responding to your letter of June 26, asking me
> to
> 	list the twenty most important cases in my field, in order
> of
> 	importance.  I have to emphasize that this is an essentially
> 	arbitrary exercise, for many reasons.
> 	
> 	 My topic is religious liberty.  It is a tight knit area with
> a
> 	manageable number of Supreme Court cases.  But it could be
> divided
> 	into three or four more homogenous subcategories, with some
> overlap;
> 	if I did that, we would of course get different results.
> 	
> 	How does the most important case in possible subcategory 1
> compare
> 	to the most important case in possible subcategory 2?  That
> depends
> 	in part on how I rate the importance of the possible
> subcategories. 
> 	It also depends on the clarity of the rules in each category;
> a
> 	single case that clearly resolves an important issue is more
> 	important than a case that introduces equally dramatic change
> but is
> 	unclear and leave s much unresolved.  Citation frequency is
> likely to
> 	depend on the number of cases the Court reviewed in each
> possible
> 	subcategory.
> 	
> 	Some cases are of great symbolic importance but little
> authority. 
> 	In this field, Everson v. Board of Education and Lemon v.
> 	Kurtzman are such cases.  They are famous and much cited but
> control
> 	almost nothing; Lemon does not make my top 20.  For this and
> other
> 	reasons, citation networks may measure something different
> from
> 	authoritativeness.
> 	
> 	A case may  be very often cited but now overruled.  Lemon is
> not
> 	there yet, but it's close.  So are Sherbert v. Verner and
> 	Wisconsin v. Yoder.  These three cases now stand for
> something very
> 	different from, and less than, what they originally stood
> for.
> 	
> 	Cases are important for different reasons, which are often
> 	incommensurable.  Cantwell v. Connecticut is a confused
> opinion on
> 	its not very important facts, but it incorporates the Free
> Exercise
> 	Clause into the Fourteenth Amendment.  How does that compare
> to an
> 	opinion that clearly resolves a dispute over a much more
> important
> 	and recurring fact pattern?
> 	
> 	West Virginia v. Barnette is important at least as much for
> its
> 	eloquence as for its rule, and cited mostly for its famous
> 	quotations.  How does that compare to authority on the
> merits?
> 	
> 	How does a statutory opinion on important facts compare to a
> 	constitutional opinion on less important facts?  How does a
> clear and
> 	decisive statutory opinion compare to a muddled
> constitutional
> 	opinion?
> 	
> 	Some cases are very important to religious liberty but are
> decided
> 	on free speech, freedom of association, the scope of
> Congressional
> 	power, or some other related ground.
> 	
> 	And so on and on.  You may hope that your mathematical
> methods will
> 	cut through all thi s qualitative uncertainty and reveal a
> true order
> 	of importance.  Maybe it will.  But it may also cumulate
> distinct
> 	reasons for citation that are not additive. 
> 	
> 	Probably you have thought about these problems.  But I had
> to
> 	mention them before give you a list that, in my view, took
> longer to
> 	produce than it is worth.  With those caveats:
> 	
> 	Topic:  religious liberty
> 	
> 	  1.  Zelman v. Simmons-Harris, 536 U.S. 639 (2002)
> 	
> 	  2.  Employment Division v. Smith, 494 U.S. 872 (1990)
> 	
> 	  3.  Church of the Lukumi Babalu Aye, Inc. v. City of
> Hialeah, 508 U.S. 520 (1993)
> 	
> 	  4.  School District v. Schempp, 374 U.S. 203 (1963)
> 	
> 	  5.  Lee v. Weisman, 505 U.S. 577 (1992)
> 	
> 	  6.  Engel v. Vitale, 370 U.S. 421 (1962)
> 	
> 	  7.  West Virginia Board of Education v. Barnette, 319 U .S.
> 624 (1943)
> 	
> 	  8.  Gonzales v. O Centro Espirita Beneficiente Uniao do
> Vegetal, 126 S.Ct. 1211 (2006)
> 	
> 	  9.  Locke v. Davey, 540 U.S. 712 (2004
> 	
> 	  10. Boy Scouts v. Dale, 530 U.S. 640 (2000)
> 	
> 	  11. Board of Education v. Mergens, 496 U.S. 226 (1990)
> 	
> 	  12. Cantwell v. Connecticut, 310 U.S. 246 (1940)
> 	
> 	  13. Good News Club v. Milford Central School, 533 U.S. 98
> (2001)
> 	
> 	  14. City of Boerne v. Flores, 521 U.S. 507 (1997)
> 	
> 	  15. Van Orden v. Perry, 125 S.Ct 2854 (2005)
> 	
> 	  16. Cutter v. Wilkinson, 544 U.S. 709 (2005)
> 	
> 	  17. Jones v. Wolf, 443 U.S. 595 (1979)
> 	
> 	  18. Everson v. Board of Education, 330 U.S. 1 (1947)
> 	
> 	  19. Wisconsin v. Yoder, 406 U.S. 205 (1972)
> 	
> 	  20. Sherbert v. Verner, 374 U.S. 398 (1963)
> 	
> 	
> 	
> 	----- End forwarded message -----
> 
> 



Paul Finkelman
Chapman Distinguished Professor of Law
Univ. of Tulsa College of Law
2120 East 4th Place
Tulsa OK  74104-3189

Phone: 918-631-3706
Fax:    918-631-2194


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