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Published online by Cambridge University Press: 01 August 2013
In the United States, the steadfast refusal of the Jehovah's Witnesses to perform some of the most basic rituals of citizenship has led champions of Americanism to cast them as unpatriotic and even seditious. The Watch Tower Society, the corporate body of the Witnesses, has responded to these accusations by presenting Witnesses as upstanding citizens, only ever departing from the letter of the law when there is a conflict between secular legal directive and scriptural injunction. This essay argues that the gulf between the popular perception of the Witnesses as poor citizens, particularly during the middle decades of the twentieth century, and the society's own representation of its members as assets to their communities highlights the contested and mutable nature of the label un-American. Furthermore, it argues that there is a paradox in the place of the Jehovah's Witnesses in modern American history: though operating beyond the pale of understood norms of citizenship, they have been fundamental to shaping the First Amendment freedoms enjoyed by all citizens. It seeks to contribute to two largely unwritten histories, namely the place of the Witnesses in American religious history, and the ever-changing yet resolutely politicized concept of the un-American.
1 Hereafter the “Watch Tower Society,” “the society,” or “the organization.”
2 Schultz, Kevin M. and Harvey, Paul, “Everywhere and Nowhere: Recent Trends in American Religious History and Historiography,” Journal of the American Academy of Religion, 78, 1 (2010), 129–62CrossRefGoogle Scholar.
3 In Introducing American Religion (London and New York: Routledge, 2009), Charles H. Lippy devotes just one paragraph of its 268 pages to the society. Furthermore, he does not acknowledge a single change in the organization since the name “Jehovah's Witnesses” was introduced in 1931.
4 The society's impact on American legal history is one of the only areas of Witness history on which there is a robust academic literature. See Henderson, Jennifer Jacobs, Defending the Good News: The Jehovah's Witnesses' Plan to Expand the First Amendment (Spokane: Marquette Books, 2010)Google Scholar; Kaplan, William, State and Salvation: The Jehovah's Witnesses and Their Fight for Civil Rights (Toronto: University of Toronto Press, 1989)Google Scholar; Manwaring, D. R., Render unto Caesar. The Flag-Salute Controversy: A Study of the Jehovah's Witnesses' Legal Struggle against Constitutional Flag Salute in Public Schools (Chicago and London: The University of Chicago Press, 1962)Google Scholar; Newton, M. O., Armed with the Constitution: Jehovah's Witnesses in Alabama and the U. S. Supreme Court, 1939–1946 (Tuscaloosa and London: University of Alabama Press, 1995)Google Scholar; Peters, S. F., Judging Jehovah's Witnesses: Religious Persecution and the Dawn of the Rights Revolution (Lawrence: University Press of Kansas, 2000)Google Scholar.
5 An exception is Penton, M. James, “Jehovah's Witnesses and the Secular State: A Historical Analysis of Doctrine,” Journal of Church and State, 21, 1 (1979), 55–72CrossRefGoogle Scholar.
6 For further discussion of the term see Lewis, G., “Introduction,” Journal of American Studies (Nov. 2013)CrossRefGoogle ScholarPubMed and the other essays in this special issue on the un-American and un-Americanism.
7 Kazin, Michael and McCartin, Joseph A., “Introduction,” in Kazin, and McCartin, , eds., Americanism: New Perspectives on the History of an Ideal (Chapel Hill: The University of North Carolina Press, 2006), 1Google Scholar.
8 Knox, Zoe, “Writing Witness History: The Historiography of the Jehovah's Witnesses and the Watch Tower Bible and Tract Society of Pennsylvania,” Journal of Religious History, 35, 2 (June 2011), 157–80CrossRefGoogle Scholar.
9 Varavka, V. and Meshavkin, S., Pravda o sektantakh (Sverdlovsk: Knizhnoe izdatel'stvo, 1960), 21Google Scholar. Suspicion of the Witnesses ran both sides of the ideological divide. Knox, Zoe, “Preaching the Kingdom Message: The Jehovah's Witnesses and Soviet Secularization,” in Wanner, Catherine, ed., State Secularism and Lived Religion in Russia and Ukraine (Oxford and New York: Oxford University Press and Woodrow Wilson Center Press, 2012), 244–71Google Scholar.
10 Henderson, 18.
11 The family name – Gobitas – was spelled incorrectly in the legal documents relating to the Supreme Court case, hence Minersville School District v. Gobitis.
12 Watch Tower Bible and Tract Society (hereafter WTBTS), The Finished Mystery (New York: WTBTS, 1917), 247Google Scholar. The Finished Mystery was the seventh volume in the Studies of the Scriptures series. Russell penned the first six; the seventh was completed posthumously by Clayton J. Woodworth and George H. Fisher, based (they claimed) on Russell's plans for the volume. This was fiercely contested and contributed to a split in the movement. See, for example, Main, C. F., Notes and Comments on “The Finished Mystery,” i.e. the Work Published under the Name of Charles Taze Russell (Adelaide: Bible Students Tract Society, 1919)Google Scholar.
13 249 US 47 (1919). The opinion established the “clear and present danger” test constraining freedom of expression.
14 WTBTS, Jehovah's Witnesses: Proclaimers of God's Kingdom (New York: WTBTS, 1993), 652Google Scholar. The documents relating to the trial can be found in The Case of the International Bible Students Association (Clayton, CA: Witnesses, Inc., 1918). On the efforts of the FBI and state police to monitor the distribution of The Finished Mystery see Jenkins, Philip, “‘Spy Mad’? Investigating Subversion in Pennsylvania, 1917–1918,” Pennsylvania History, 63, 2 (Spring 1996), 204–31, 210–11Google Scholar.
15 Cited in “20 Years in Prison for 7 Russellites,” New York Times, 22 June 1918, 18.
16 Jenkins, 215.
17 An extract is reproduced in “Modern History of Jehovah's Witnesses, Part 8: International Attempt to Destroy Society Fails,” Watchtower, 15 April 1955, 236–39. William O. Douglas, the associate Supreme Court justice who served from 1939 to 1975, would agree with the petition's sentiments: he gave the following first amongst a list of what un-American means: “Discrimination against racial, religious, or other minorities” and “Denial to anyone of the right of free speech.” Douglas, William O., An Almanac of Liberty (London and Glasgow: Collins, 1954), 122Google Scholar.
18 The society's rhetoric has been anti-Catholic and anti-Protestant since the 1920s, most vehemently during the Rutherford era. See Rutherford, Joseph F., Enemies (New York: WTBTS, 1937)Google Scholar.
19 See the cases of persecution in 1918 recounted in “Distress of Nations: Cause, Warning, Remedy,” Golden Age, 29 Sept. 1920, 712–17. The Witnesses were not the only group subjected to mob violence, of course: German Americans were targeted by vigilantes in 1918. Luebke, Frederick C., Bonds of Loyalty: German-Americans and World War I (De Kalb: Northern Illinois University Press, 1974), 279–81Google Scholar.
20 Coben, Stanley, “A Study in Nativism: The American Red Scare of 1919–20,” Political Science Quarterly, 79, 1 (1964), 52–75, 59, 53CrossRefGoogle Scholar. See also Pencak, William, For God and Country: The American Legion, 1919–1941 (Boston: Northeastern University Press, 1989), 144–69Google Scholar.
21 National Archives Building, Washington, DC (hereafter NAB): RG 267 US Supreme Court, Appellate Case Files, 688 O. T. 1939, 690 O. T. 1939, Box no 1943 E 21 (2 of 2)
22 310 US 586 1940. Justice Harlan F. Stone dissented.
23 See, for example, the following, which suggest that the ruling might be prompted by war hysteria: New Republic, 24 June 1940, 843; Christian Century, 3 July 1940, 845–46. See also Justice Stone's dissent.
24 316 US 584 (1942).
25 319 US 105 (1943). Sandmann, Warren, “West Virginia State Board of Education v. Barnette,” in Parker, Richard A., ed., Free Speech on Trial: Communication Perspectives on Landmark Supreme Court Decisions (Tuscaloosa: University of Alabama Press, 2003), 103–4Google Scholar. For opposing views on the reasons for the reversal see Peters, Judging Jehovah's Witnesses, 230–59; and Richards, Neil M., “The ‘Good War,’ the Jehovah's Witnesses, and the First Amendment,” Virginia Law Review, 87, 4 (June 2001), 781–811, 793–96CrossRefGoogle Scholar.
26 319 US 624 1943.
27 Barber argued that in seven favourable rulings in May and June 1943, of which Barnette was one, “the Supreme Court seemed to go over completely to the Witness camp.” Barber, Hollis W., “Religious Liberty v. Police Power: Jehovah's Witnesses,” American Political Science Review, 41, 2 (April 1947), 226–47, 235CrossRefGoogle Scholar.
28 Peters, 89.
29 Cited in Bremer, J. C., In Defense of That Despised Sect (Metropolis, Illinois: J. C. Bremer Printing Service, no date (probably 1940s)), 10Google Scholar.
30 American Civil Liberties Union, The Persecution of Jehovah's Witnesses: The Record of Violence against a Religious Organization Unparalleled in America since the Attacks on the Mormons (New York City: American Civil Liberties Union, 1941), 3Google Scholar.
31 Franklin D. Roosevelt, “52. ‘At This Time When the World Is Threatened by Forces of Destruction, It Is My Resolve and Yours to Build up Our Armed Defenses.’ Fireside Chat on National Defense, May 26, 1940,” The Public Papers and Addresses of Franklin D. Roosevelt: War – And Aid to Democracies 1940, vol. 9, ed. Samuel I. Rosenman (New York: Russell & Russell, 1969), 238.
32 Peters, 72–73.
33 Cole, Marley, Jehovah's Witnesses: The New World Society (London: George Allen & Unwin, 1956), 120Google Scholar. The account given by the society reveals the scale of the violence. It reported that since May 1940, “Jehovah's witnesses have been assaulted, beaten, kidnaped [sic], driven out of towns, counties and states, tarred and feathered, forced to drink castor oil, tied together and chased like dumb beasts through the streets, castrated and maimed, taunted and insulted by demonized crowds, jailed by the hundreds without charge and held incommunicado and denied the privilege of conferring with relatives, friends or lawyers. Many other hundreds have been jailed and held in so-called ‘protective custody’; some have been shot in the nighttime; some threatened with hanging and beaten into unconsciousness. Numerous varieties of mob violence have occurred. Many have had their clothes torn from them, their Bibles and other literature seized and publicly burned; their automobiles, trailers, homes and assembly places wrecked and fired, resulting in damages totaling very many thousands of dollars.” WTBTS, 1941 Yearbook of Jehovah's Witnesses (New York: WTBTS, 1940), 97Google Scholar.
34 WTBTS, Jehovah's Witnesses in the Divine Purpose, 1st edn (New York: WTBTS, 1959), 180Google Scholar; WTBTS, 1941 Yearbook of Jehovah's Witnesses (New York: WTBTS, 1940), 96Google Scholar. It is estimated that Legionnaires were involved in over one-fifth of the assaults on Witnesses in the early 1940s. Manwaring, Render unto Caesar, 175–76.
35 Henderson, Defending the Good News, 20.
36 Ibid., 21.
37 American Civil Liberties Union, In Defense of Our Civil Liberties: A Report of the American Civil Liberties Union in the Third Year of the War (New York: American Civil Liberties Union, 1944), 52–53Google Scholar.
38 Not a single incident involving the Witnesses appears in ACLU, Liberty on the Home Front in the Fourth Year of War (New York: American Civil Liberties Union, 1945).
39 Louis Beehler of Scotland, South Dakota, one of the “Nazi agents,” reportedly told the crowd, “If we have to go there will be hundreds to take our place. They will flow from all corners. They are in every county in Texas, every State in the union and every country in the world.” “Texas Crowd Expels Nazi Pamphleteers,” New York Times, 23 May 1940, 14.
40 “Sect Active in Del Rio,” New York Times, 24 May 1940, 13.
41 WTBTS, Jehovah's Witnesses: Communists or Christians?, flyer, undated. The pamphlet was probably produced in 1951, ironically the same year that Stalin ordered the mass deportation of Witnesses from the Soviet Union's western borderlands to Siberia.
42 New World Bible Translation Committee, New World Translation of the Holy Scriptures (New York: WTBTS, 1984), 1351Google Scholar. For a discussion of the scriptural basis of neutrality and its application in different historical contexts see WTBTS, Jehovah's Witnesses: Proclaimers, 188–201.
43 Russell, Charles T., The New Creation (Brooklyn, NY: WTBTS, 1925), 594Google Scholar.
44 Russell, Charles T., The Battle of Armageddon (Brooklyn, NY: WTBTS, 1924), 144Google Scholar.
45 WTBTS, “Rival Kings in Conflict,” Watchtower, 1 April 1984, 16–20Google Scholar. For a detailed discussion of the Cold War in Witness theology see Knox, Zoe, “The Watch Tower Society and the End of the Cold War: Interpretations of the End-Times, Superpower Conflict, and the Changing Geo-political Order,” Journal of the American Academy of Religion, 79, 4 (Dec. 2011), 1018–49CrossRefGoogle Scholar.
46 The futility of bloc politics is made clear in an address by Rutherford's successor: Knorr, Nathan H., “When All Nations Unite under God's Kingdom,” Watchtower, 15 October 1961, 612–26Google Scholar.
47 Boyer, Paul S., When Time Shall Be No More: Prophecy Belief in Modern American Culture (Cambridge, MA: Harvard University Press, 1992), 225–53Google Scholar.
48 “What Are Jehovah's Witnesses Like?”, Awake!, 8 Nov. 1974, 17–21. Note that the upper-case W for Witnesses was not used by the society until 1976. Newspaper reports which are at best impartial frequently refer to the Witnesses' exemplary behaviour at these large gatherings. See High, Stanley, “Armageddon, Inc.,” Saturday Evening Post, 14 Sept. 1940, 19Google Scholar, which emphasized their subdued demeanour thus: “Judging from all outward appearances, this might have been a midsummer gathering of Kansas Methodists.”
49 “ ‘Be in Subjection’ – To Whom?”, Watchtower, 1 Nov. 1962, 649–58, 658.
50 Such is the emphasis upon exemplary behaviour that the society disciplines poor conduct within its own congregations. “What Makes a Good Citizen,” Awake!, 8 Sept. 1999, 26–27.
51 “United States District Assemblies of 1949,” Watchtower, 15 Jan. 1950, 28–31. The American Legion and the Jehovah's Witnesses share a mutual loathing which, at times, resembles competition. See ibid. and Kaplan, Morris, “Sect Assailed at Legion Parley,” New York Times, 2 Aug. 1958, 19Google Scholar.
52 “What Are Jehovah's Witnesses Like?”, 18.
53 New World Bible Translation Committee, New World Translation of the Holy Scriptures, 1418.
54 Penton, “Jehovah's Witnesses and the Secular State,” 55–72.
55 WTBTS, Life Everlasting in Freedom of the Sons of God (Brooklyn, NY: WTBTS, 1966), 188–218Google Scholar.
56 ACLU, “Kentucky Supreme Court Upholds Convictions in Amish Buggy Dispute,” 25 Oct. 2012, at www.aclu.org/religion-belief/kentucky-supreme-court-upholds-convictions-amish-buggy-dispute, accessed 17 April 2013.
57 WTBTS, Fighting for Liberty on the Home Front (New York: WTBTS, 1943), 8–9Google Scholar.
58 Similarly, the society adopted the ideologically inflected language of the Cold War era in its publications, referring to the USSR's “totalitarian government and dictatorship.” “Part 30 – ‘Your Will Be Done on Earth’,” Watchtower, 15 Jan. 1960, 56–60.
59 American Civil Liberties Union, Jehovah's Witnesses and the War (New York: ACLU, 1943), 7Google Scholar.
60 “Jehovah's witnesses do not interfere with the program of any nation in fostering patriotism. They do not contest the right of others to engage in these ceremonies, if they choose to do so … They only seek freedom to worship God without molestation, which the law provides.” “Patriotism and Religious Freedom,” Watchtower, 15 Nov. 1962, 700–2.
61 “District Assemblies during 1952,” Watchtower, 15 Dec. 1952, 748. It is probable that the society also meant to refer to the Legion's history of vigilantism by the “un-American position of the Legion.”
62 Kazin and McCartin, “Introduction,” 1.
63 WTBTS, Truth Shall It Be Suppressed or Will Congress Protect the People's Rights? (New York: WTBTS, 1934), 38Google Scholar.
64 Ruth E. Martin, “American Civil Liberties, Fear and Conformity, 1937–1969,” PhD dissertation, University of Cambridge, 2012.
65 The “rights which their court contests seek to uphold are the rights applicable to all persons; and their success in establishing them has been of immense benefit to the cause of civil liberties generally.” American Civil Liberties Union, Jehovah's Witnesses and the War, 9.
66 WTBTS, Jehovah's Witnesses in the Divine Purpose, 17; WTBTS, Jehovah's Witnesses: Proclaimers, 557.
67 “Annual Report,” Watch Tower and Herald of Christ's Presence, 37, 24 (1916), 6021–22 (CD ROM: Magazines that Motivate).
68 Bill Davidson, “Jehovah's Traveling Salesmen,” Collier's, 2 Nov. 1946, 12–13.
69 Cited in Henderson, Defending the Good News, 65–66.
70 WTBTS, Freedom of Worship (New York: WTBTS, 1943), 61Google Scholar.
71 303 US 444 1938.
72 NAB: RG 267 US Supreme Court, Appellate Case Files, 391 O. T. 1937, 392 O. T. 1937, Box no 1097.
73 NAB: RG 267 US Supreme Court, Appellate Case Files, 391 O. T. 1937, 392 O. T. 1937, Box no 1097, 17.
74 303 US 444 1938.
75 NAB: RG 267 US Supreme Court, Appellate Case Files, 391 O. T. 1937, 392 O. T. 1937, Box no 1097.
76 Henderson, 23.
77 An extensive course of Bible study and sustained involvement with the Kingdom Hall is essential before one may be accepted for baptism. Readiness is ultimately decided by an elder after a 100-question survey has been administered. Baptism takes place at the annual conventions and circuit assemblies in large pools brought in expressly for this purpose. For an explanation of the society's understanding of ministers see WTBTS, Qualified to Be Ministers (New York: WTBTS, 1955; revised 1967)Google Scholar.
78 Morris argues that lack of formal direction from the society meant that Witnesses in Arkansas had a range of responses to the draft, and that for draftees “the line between conscientious objector status and ministerial status was very thin.” Morris, Cynthia Hastas, “Arkansas's Reaction to the Men Who Said ‘No’ to World War II,” Arkansas Historical Quarterly, 43, 2 (Summer, 1984), 153–77, 158Google Scholar.
79 Cole, Jehovah's Witnesses, 121. Cole's wording is ambiguous but does suggest that this figure was given by Hayden Covington.
80 Sibley, Mulford Q. and Jacob, Philip E., Conscription of Conscience: The American State and the Conscientious Objector, 1940–1947 (Ithaca: Cornell University Press, 1952), 71Google Scholar.
81 The increased public antipathy toward the Witnesses after the United States entered the war, coupled with confrontations between Witnesses and local residents, led one board to deny Albert Blakeley, a Witness from Geyer Springs, Arkansas, the IV-D status. Morris, 160–65.
82 Some 3,992 Witnesses were convicted of violating the Selective Training and Service Act, broken down as follows: 2,519 for failure to comply with induction orders, 1,456 for failure to comply with assignments to civilian work, and 17 for miscellaneous violations. Elliff, Nathan T., “Jehovah’'s Witnesses and the Selective Service Act,” Virginia Law Review, 31, 4 (Sept. 1945), 811–34, 811CrossRefGoogle Scholar.
83 Sibley and Jacob, 85. In 1944, Jehovah's Witnesses received an average sentence of 42 months in jail, whereas conscientious objectors received an average of 34 months and other violators of the Act 28 months and three days. Ibid., 498.
84 346 US 389 1953.
85 NAB: RG 267 US Supreme Court, Appellate Case Files – 57 O. T. 1953–60 O. T. 1953, Box no 410, File 57 O. T. 1953, 9.
86 WTBTS, Freedom of Worship, 34.
87 NAB: RG 267 US Supreme Court, Appellate Case Files – 57 O. T. 1953–60 O. T. 1953, Box no 410, File 57 O. T. 1953, 10. Covington's allegation is supported in Sibley and Jacob, 71. For an opposing view see Elliff, 821.
88 The Supreme Court decided this question in Sicurella v. United States (348 US 385 1955). It reversed the decision of a local board to deny Anthony Sicurella, a Jehovah's Witness, the status of conscientious objector on the grounds that he was willing to use force to defend his ministry and his fellow Witnesses and to fight in “theocratic wars,” i.e. those directed by Jehovah. The Court ruled, “We believe that Congress had in mind real shooting wars when it referred to participation in war in any form [in the Universal Military Training and Service Act] – actual military conflicts between nations of the earth in our time – wars with bombs and bullets, tanks, planes and rockets.”
89 NAB: RG 267 US Supreme Court, Appellate Case Files – 57 O. T. 1953–60 O. T. 1953, Box no 410, File 57 O. T. 1953, 92.
90 NAB: RG 267 US Supreme Court, Appellate Case Files – 57 O. T. 1953–60 O. T. 1953, Box no 410, File 57 O. T. 1953, 59. For further discussion of legal rulings on the issue of minister as vocation and paid employment see “Can You Prove You Are a Minister?”, Awake!, 22 Oct. 1964, 13–15.
91 346 US 389 1953.
92 In the 1960s, Covington argued that Cassius Clay (better known as Muhammad Ali) should be exempt from military service under the IV-D classification as a black Muslim minister. This was rejected.
93 WTBTS, Jehovah's Witnesses in the Divine Purpose, 228.
94 The title of this section is that of a chapter describing the society's legal campaigns in the United States in WTBTS, Jehovah's Witnesses in the Divine Purpose.
95 For accounts by key Watch Tower lawyers see Blackwell, V., O'er the Ramparts They Watched (Aurora, MO: Stoops Manufacturing Company, 1976)Google Scholar; and Jerry Murray and his wife (name withheld), “Interview with Watchtower Attorney Hayden Covington,” 19 Nov. 1978.
96 Wolfe, Alan, “Religious Diversity: The American Experiment That Works,” in Kazin, and McCartin, , Americanism, 153–66, 160Google Scholar.
97 “The Legion – Watchdog of American Freedom?”, Awake!, 8 Sept. 1950, 3.
98 Henderson, J. J., “The Jehovah's Witnesses and Their Plan to Expand First Amendment Freedoms,” Journal of Church and State, 46, 4 (2004), 811–32, 832CrossRefGoogle Scholar.
99 Henderson, “The Jehovah's Witnesses and Their Plan,” 817. Whilst there are similarities in the provocative tactics employed by Covington and those later used by the National Association for the Advancement of Colored People and the Southern Christian Leadership Conference, these only go so far: as in his publications, Rutherford's speeches strongly condemned the Vatican, aligning it with Satan, and, not surprisingly, deeply offended Catholic listeners.
100 The ACLU's representation of the Witnesses is described in detail in Peters, Judging Jehovah's Witnesses.
101 WTBTS, Freedom of Worship (New York: WTBTS, 1943), 55Google Scholar.
102 310 US 296 1940.
103 “Jehovah's Witnesses claimed tolerance for their intolerance; they had a right, they argued, to condemn all other beliefs.” Gordon, Sarah Barringer, The Spirit of the Law: Religious Voices and the Constitution in Modern America (Cambridge, MA and London: The Belknap Press of Harvard University Press, 2010), 41Google Scholar.
104 Covington, Hayden, Defending and Establishing the Good News (New York: WTBTS, 1950), 5Google Scholar.
105 High, “Armageddon, Inc.,” 19
106 See Coben, “A Study in Nativism”; Kovel, Joel, Red Hunting in the Promised Land: Anticommunism and the Making of America (New York: BasicBooks, 1994)Google Scholar; Heale, M. J., “Anatomy of a Scare: Yellow Peril Politics in America, 1980–1993,” Journal of American Studies, 43, 1 (2009), 19–47CrossRefGoogle Scholar; Cimino, Richard, “‘No God in Common’: American Evangelical Discourse on Islam after 9/11,” Review of Religious Research, 47, 2 (Dec. 2005), 162–74CrossRefGoogle Scholar.
107 For example, the William Gobitas Papers are held in the Library of Congress. There is one key document which cannot be found amongst the papers, however: a letter from William (Billy) Gobitas dated 5 November 1935 to the directors of his school explaining why he refused to salute the flag. It has been pulled from the files to become part of the core collection of the Manuscript Reading Room, one of ninety items the archivists determined most precious, sitting alongside the petition for bail from accused witches around 1692, the Indian treaty signed at Portsmouth, New Hampshire in 1713, the draft of Frederick Douglass's autobiography and other manuscripts marking defining moments in the creation of modern America.
108 In Hosanna-Tabor Evangelical Lutheran Church and School v. Equal Employment Opportunity Commission (565 US 2012), the Supreme Court upheld a religious school's right to dismiss an employee on the grounds that the state should not determine who can be appointed a minister, thus freeing the school from the obligations of federal equal-opportunity legislation. At the time of writing, the relevant United States Report had yet to be bound, hence incomplete citation.
109 “Modern History of Jehovah's Witnesses: Part 14 – Fight Carried into the Law Courts,” Watchtower, 15 July 1955, 425.
110 Waite, Edward F., “The Debt of Constitutional Law to the Jehovah's Witnesses,” Minnesota Law Review, 28, 4 (March 1944), 209–46, 244Google Scholar.
