such laws unconstitutional as an unreasonable interference
with the liberty of parents and guardians to direct the
education of their children. ¹

In a case arising from Oregon in 1925 where the law
forbade all private school teaching, the Court helds ² that
the liberty guaranteed by the Fourteenth Amendment
excluded any power of the state "to standardize its children
by forcing them to accept instruction from public teachers
only." However, Justice McReynolds in the decision
intimated that the state had the power to require that
teachers should be of "patriotic disposition."

We have already discussed under the heading Public
Employees the problems which have arisen from laws
designed to eliminate so-called "subversive" teachers. And
in the preceding section dealing with religious freedom
we have analyzed the "flag salute" cases ³ and those in-
volving the problems of religious instruction of school
children. ⁴

The Constitution leaves the qualifications for voting to
the states, the only restriction being that there can be no
discrimination based on race, color, previous servitude or
sex.

Although at one time the Supreme Court had ruled
that primary elections for national offices were entirely
outside the scope of federal supervision, it later con-
cluded otherwise, at least in states where the primary was
part of the election machinery or where, as in certain
Southern states, the result in the primary determined the
election. ⁸, ⁹ In 1953 this rule was extended to reach an
informal all-white primary in Texas. ¹⁵

Attempts by Congress to supervise elections for offices
other than national offices have been held unconstitutional. ¹
On the other hand, the Supreme Court has upheld legisla-
tion regulating elections for members of Congress or for

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