made it clear that applicants for citizenship now need
not agree to perform any military service whatever, whether
combatant or non-combatant. 15

The troublesome question of aid to church schools has
received attention from the Supreme Court several times
in the past few years. The Court unanimously expressed
the opinion that the First Amendment compels the com-
plete separation of church and state, and bans direct aid
to religion. In the Everson case ¹² the majority of the
Court decided that payment of bus fares to parents of
parochial school children was permissible since it was not
aid to the school but to the parents. In the McCollum
case ¹⁴ the Court decided that religious instructions given
in school buildings violated the constitutional ban.

But in the Zorach case ¹⁷ a majority of the Court,
headed by Justice Douglas, upheld New York's "released
time" program which permitted parents to have their
children excused for religious instruction (given outside
the school) for one hour a week. Justices Black, Frank-
furter and Jackson wrote separate dissenting opinions. We
quote from that of justice Jackson:

"As one whose children, as a matter of free choice, have been
sent to privately supported Church schools, I may challenge the
Court's suggestion that opposition to this plan can only be anti-
religious, aesthetic, or agnostic. My evangelistic brethren confuse
an objection to compulsion with an objection to religion. It is
possible to hold a faith with enough confidence to believe that
what should be rendered to God does not need to be decided
and collected by Caesar."

The Supreme Court has given protection to a right
nowhere mentioned in the Constitution: freedom of teach-
ing. Hysteria of the First World War period produced
laws prohibiting the teaching of German and other foreign
languages. In a series of cases the Supreme Court held

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