The Establishment Clause states: "Congress shall make no law respecting an establishment of religion." [11], Congressional sessions open with the recital of the Pledge, as do many government meetings at local levels, and meetings held by many private organizations. Lawmakers had intended them to be part of instruction on . [12] Many states give a variety of exemptions from reciting the pledge, such as California which requires a "patriotic exercise" every day, which would be satisfied by the Pledge, but it is not enforced. The Pledge Of Allegiance was written by Francis Bellamy in August 1892. , 26 Feb. 2019, thehill.com/opinion/education/431719-can-schools-require-students-to-say-the-pledge-of-allegiance. Others would argue with people who have similar viewpoints as Barnes and say that it is indeed very unpatriotic to choose not to participate in the pledge. It is crucial to teach the rising generation that, as Americans, the cause for this nations freedom will one day rest in their hands. But critics say there's still pressure on students to . The 1943 U.S. Supreme Court ruling . - Definition, History & Types, What Is Academia? The changes made in 1954 still stand today, reading: "I pledge allegiance to the flag of the United States of America, and to the republic for which it stands, one nation under God, indivisible, with liberty and justice for all." The district court held that the compulsory flag salute violated the religious freedom clause when enforced against the Jehovahs Witnesses, and the circuit court of appeals affirmed this decision. He was told countless times by teachers to stand for the flag. This was Eisenhower's way to reiterate America's differences from the communist Soviet Union. None explicitly demanded pupils participate in the ceremony as it was, at the time, almost inconceivable that anyone might refuse. By June 29, 1892, Bellamy and Upham had arranged for Congress and President Benjamin Harrison to announce a proclamation making the public school flag ceremony the center of the Columbus Day celebrations. Subscribe to The Bradford weekly e-newsletter! May it Please the Court, The Court case Alex v. Upper Arlington School District, a student named Alex refused to stand for the Pledge of Allegiance in the early hours of school. This article is about the oath spoken to the U.S. flag. The First Amendment Encyclopedia, Middle Tennessee State University (accessed Mar 01, 2023). [29] According to author Margarette S. Miller, this campaign was in line both with Upham's patriotic vision as well as with his commercial interest. 8. On four occasions in the 1930s the Supreme Court refused petitions for certiorari from these rulings. [44], On October 6, 1954, the National Executive Committee of the American Legion adopted a resolution, first approved by the Illinois American Legion Convention in August 1954, which formally recognized the Knights of Columbus for having initiated and brought forward the amendment to the Pledge of Allegiance. [77], In February 2015 New Jersey Superior Court Judge David F. Bauman dismissed a lawsuit, ruling that " the Pledge of Allegiance does not violate the rights of those who don't believe in God and does not have to be removed from the patriotic message. The first version, with a text different from the one used at present, was written in 1885 by Captain George Thatcher Balch, a Union Army officer in the Civil War who later authored a book on how to teach patriotism to children in public schools. Students were instructed to stand with their right hand stretched out towards the flag. Mark Alcorn is a high school and college history instructor in Minnesota. "[28], Bellamy considered the slogan of the French Revolution, Libert, galit, fraternit ("liberty, equality, fraternity"), but held that "fraternity was too remote of realization, and [that] equality was a dubious word. However, the original Pledge has been altered several times since then. Since the mid-twentieth century, the federal courts have placed limits upon state power to require or even permit these popular cultural practices. - Definition & History, The Law of 1642, the Old Deluder Satan Act, & U.S. Public Education, Psychology's Impact on Education: Help and Review, Major Philosophies of Education: Help and Review, Education Court Cases & Legislation: Help & Review, School and System Governance: Help and Review, National Professional Organizations in Education: Help and Review, Reading Development & Teaching Strategies, CEOE Early Childhood Ed: Language Development, CEOE Early Childhood Ed: Teaching Language & Literacy, CEOE Early Childhood Ed: Teaching Reading Comprehension, CEOE Early Childhood Ed: Writing Instruction, CEOE Early Childhood Ed: Cognitive Development, CEOE Early Childhood Ed: Cognition & Memory, CEOE Early Childhood Ed: Diversity in the Classroom, CEOE Early Childhood Ed: Motivating Students, CEOE Early Childhood Ed: Instructional Pedagogy, CEOE Early Childhood Ed: Assessment Strategies, CEOE Early Childhood Ed: Basic Math & Problem Solving, CEOE Early Childhood Ed: Foundations of Science, CEOE Early Childhood Ed: Health & Physical Education, CEOE Early Childhood Ed: Social & Moral Development, CEOE Early Childhood Ed: Socialization Strategies, CEOE Early Childhood Ed: Resources & Technology. Pennsylvania and Massachusetts alone expelled over two hundred Jehovahs Witness children from school. Regardless of the Supreme Courts ambivalence, this statutory recitation, which includes the phrase under God, directly violates the right to freedom of religion. Yes, my I did support my children - one 31, and the other who will be 29 in April - swearing the pledge of allegiance daily whe they were in elementary & intermediate schools. http://mtsu.edu/first-amendment/article/1137/pledge-of-allegiance, The Free Speech Center operates with your generosity! Dedicated to social issues, he donated all rights of the musical setting to the U.S. government, so that anyone can perform the piece without owing royalties. [citation needed]. This arrangement was formalized when Harrison issued Presidential Proclamation 335. The substitute teacher didn't know that students can't be compelled to participate in the pledge, the school district said. Today, the words of the Pledge of Allegiance reads: I pledge allegiance to the Flag of the United States of America and to the Republic for which it stands, one Nation under God, indivisible, with liberty and justice for all. Schools should teach the forgotten history of the Pledge of Allegiance There's a story for students about how those 31 words came to be. "[28] After working on the idea with Upham, Bellamy concluded, "It was my thought that a vow of loyalty or allegiance to the flag should be the dominant idea. Although his focus was on the unity of the nation, over the years controversial changes have been made to the Pledge of Allegiance. Kruse acknowledges the insertion of the phrase was influenced by the push-back against Soviet and Chinese atheistic communism during the Cold War, but argues the longer arc of history shows the conflation of Christianity and capitalism as a challenge to the New Deal played the larger role.[39][relevant? schools is unconstitutional because it "violates the religion clauses of the Constitution" (i.e., the First Amendment protection that "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof"). Back in 1954, in one providential phrase, Congress purifiedand perhaps redeemedthe Pledge of Allegiance as an enduring expression of Christian patriotism. The problem with the Pledge of Allegiance is thus rooted far deeper than just the phrase under God.. - Christopher Columbus, The Pledge Of Allegiance And 'Under God' - Yes, There's A Connection MARTIN: Well, I think most of us recognize those words as the Pledge of Allegiance. States that require the pledge be recited, with no clear exemptions. The words "Under God" were officially added in 1954. Your email address will not be published. He argued that the nation's might lay not in arms but rather in its spirit and higher purpose. But, as CNN reported in 2019, its still "recited in schools across the US every day by students standing stiffly with their hands over their hearts.". When trying to understand which schools still say the pledge and which do not, local demographics, organizational values, and political convictions are the strongest determining factors. First-grade students in Baltimore say the Pledge of Allegiance to the American flag in June 1955. Credit: Richard Stacks/Baltimore Sun/Tribune News Service via Getty Images. One parent said her children recited the pledge "every day in school last year.". Please, Issues Related to Speech, Press, Assembly, or Petition, Conscientious Objection to Military Service, http://mtsu.edu/first-amendment/article/1137/pledge-of-allegiance. Until the onset of the Second World War, Bellamys original pledge even featured a hand salute that appears indistinguishable from the Nazi salute. "[28] Concluding "Liberty and justice were surely basic, were undebatable, and were all that any one Nation could handle. [42], At the suggestion of a correspondent, Representative Louis C. Rabaut (D-Mich.), of Michigan sponsored a resolution to add the words "under God" to the Pledge in 1953. Cornell Law School, West Virginia State Board of Education et al. Encyclopedia Table of Contents | Case Collections | Academic Freedom | Recent News, Americas most common form of paying respect to a national emblem or symbol, the flag salute with the Pledge of Allegiance, started as part of a nationwide public school observance in 1892 honoring the four-hundredth anniversary of Columbuss discovery of America. In most instances these children still faced compulsory education laws, meaning they had to enroll in private schools or be liable to prosecution. Both sides of the controversy should be addressed in school so children do not just follow their parents and can make this decision for themselves. Freedom Forum Institute, Sept. 18, 2017. It is not enough to simply repeat the words liberty and justice for all if students have no concept of what that effort entails. If they were exercised for all. The Supreme Court has ruled that compelling schoolchildren to recite the Pledge of Allegiance violates the First Amendment. By 1942, the United States government officially recognized the pledge as an American symbol of patriotism and promptly ruled that no American should be compelled to recite it against his or her will. Shawnta S. Barnes, a teacher at a public school, does not say the pledge during the morning announcements with her class and the rest of the school. Students who develop a genuine sense of gratitude for the sacrifices of countless Americans will grow to be adults who are unafraid of continuing to make those sacrifices. Its why we sing the anthem and say the pledge at frivolous or recreational events, like football games and paradesbecause without those who have died protecting us, we would not have the luxury of devoting our time and attention to such gatherings. The Witnesses were decidedly unpopular in the 1930s and 1940s because of their methods of aggressive proselytizing and their repeated and severe condemnations of other religions. According to Miller, Upham "would often say to his wife: 'Mary, if I can instill into the minds of our American youth a love for their country and the principles on which it was founded, and create in them an ambition to carry on with the ideals which the early founders wrote into The Constitution, I shall not have lived in vain. Today, students still recite the Pledge of Allegiance in classrooms throughout the United States, though virtual learning has recently complicated this morning routine. The National Fraternal Congress meeting in Boston on September 24, 1952, adopted a similar resolution upon the recommendation of its president, Supreme Knight Luke E. Hart. There have also been concerns with the words, under God that are written in the pledge due to many religious controversies, and especially since religion is not supposed to be taught in schools. An image thats being shared widely on social media reminiscences about the old days, and bemoans the political-correctness of contemporary times. The History of Legal Challenges to the Pledge of Allegiance. National Constitution Center, 14 June 2019, constitutioncenter.org/blog/the-latest-controversy-about-under-god-in-the-pledge-of-allegiance. In 1943, the Supreme Court reversed their decision, citing it as unethical to force beliefs or principles. In 1924, the phrase my flag was replaced with the phrase the flag of the United States of America to help clarify the focus of the recitation and to promote the American ideal of unity. In modern usage, the Gettysburg Address might read "that the nation shall, God willing, have a new birth of freedom." While youngsters have the right to refrain from reciting the Pledge, some school officials still try to force it. The decision had ushered in a period of violence perpetrated against Jehovahs Witnesses. New York: Harcourt, Brace and World, 1963. In 1923, the National Flag Conference called for the words "my Flag" to be changed to "the Flag of the United States," so that new immigrants would not confuse loyalties between their birth countries and the US. This daily routine continues on through high school in most cases. At Whittier Tech in Massachusetts, "each day, teachers will take attendance, classes will say the pledge of allegiance and announcements will be given," according to a Sept. 18 press release from the high school about welcoming students back to campus. As early as 1918, the Mennonites, among others, refused the salute and pledge because they thought it implied a promise to bear arms, and for the most part, school officials chose to grant exemptions. 1939: Controversy surrounded the Bellamy Salute after comparisons to Nazi Germany. Docherty's Sermon Manuscript, Feb. 7, 1954, https://en.wikipedia.org/w/index.php?title=Pledge_of_Allegiance&oldid=1141367888, Pages using cite court with unknown parameters, Short description is different from Wikidata, All Wikipedia articles written in American English, Articles with unsourced statements from February 2016, All articles that may have off-topic sections, Wikipedia articles that may have off-topic sections from October 2022, Pages using Sister project links with hidden wikidata, Pages using Sister project links with default search, Creative Commons Attribution-ShareAlike License 3.0, "I pledge allegiance to my Flag and the Republic for which it stands, one nation, indivisible, with liberty and justice for all. As if it wasn't bad enough being a small refugee child living without your parents in an old Walmart, apparently at least one immigration jail (sorry, Detention Facility) makes children recite the Pledge of Allegiance each morning.According to an immigration official, it's "out of respect" for the country, though it's unclear why a bewildered Guatemalan child should owe "allegiance . Politics is the reason the Pledge of Allegiance is recited every day in our schools. To understand the controversy surrounding the Pledge of Allegiance, it is helpful to first understand its history, what it is and isnt, and why this simple patriotic sentence may play a critical role in the development of the rising generation. Thus, the Court did not consider the constitutional question, and under God is still in the pledge that primary and secondary teachers are required to lead in some states. [28], As the World's Columbian Exposition was set to celebrate the 400th anniversary of the arrival of Christopher Columbus in the Americas, Upham sought to link the publication's flag drive to the event, "so that every school in the land would have a flag raising, under the most impressive conditions. On January 3, 2005, a new suit was filed in the U.S. District Court for the Eastern District of California on behalf of three unnamed families. Today, 46 states require schools to have a time to recite it. , 14 Nov. 2018, educationpost.org/im-a-teacher-and-i-stopped-saying-the-pledge-of-allegiance-a-long-time-ago/. Pledge Timeline September 9, 1892: The pledge is introduced in the magazine The Youth's Companion as part of a program to celebrate Columbus Day in schools across the country. '"[30] In 1957, Kenneth Keating instigated a report by Congress' Legislative Research Service that it was Francis Bellamy, and not James B. Upham, who authored the September 8, 1892 article; Keating represented New York's 38th congressional district, which included Bellamy's birthplace, Mount Morris. My problem with the pledge philosophically is just the idea that you have to give yourself to your state in a mandatory sort of way, which cheapens the sacrifice of those who make that decision voluntarily, said Mr. Kyle Gekopi, a social studies teacher at the high school. "[28] The publication's efforts paid off when Benjamin Harrison declared Wednesday October 12, 1892, to be Columbus Day for which The Youth's Companion made "an official program for universal use in all the schools. Millions of American children still begin their school day with . The recitation of the Pledge of Allegiance "renders unto Caesar the things that are Caesar's" in patriotism, and it also "renders unto to God the things that are God's" in Christian piety (see Mark 12:13-17). Enrolling in a course lets you earn progress by passing quizzes and exams. He responded enthusiastically to Docherty in a conversation following the service. Washington, DC fine when there is real love and respect. The schools would be included in the pledge. Bomboy, Scott. [45], The phrase "under God" was incorporated into the Pledge of Allegiance on June 14, 1954, by a Joint Resolution of Congress amending 4 of the Flag Code enacted in 1942. The very patriotic values claimed to be strengthened by the pledge are weakened by its compulsory nature. To the Flag: The Unlikely History of the Pledge of Allegiance. It is a critical part of building our nation. The pledge was written in 1892 by Francis Bellamy, a socialist minister, to commemorate Columbus Day, a holiday that the school no longer observes due to Columbus own dubious history. It was initially published in The Youth's Companion on September 8, 1892. [63] They said requiring the pledge violated their freedom of religion guaranteed by the Free Exercise Clause of the First Amendment. Andrew has worked as an instructional designer and adjunct instructor. Example: [Collected on the Internet, 2002]. In 1943, a law was passed stating that students could not be forced to stand or say the Pledge of Allegiance. . The Pledge of Allegiance has been an ongoing controversy in recent years. [36], During the Cold War era, many Americans wanted to distinguish the United States from the state atheism promoted by Marxist-Leninist countries, a view that led to support for the words "under God" to be added to the Pledge of Allegiance. [25] Francis Bellamy, who was a Baptist minister, a Christian socialist,[26][27] and the cousin of Edward Bellamy (18501898), described the text of Balch's pledge as "too juvenile and lacking in dignity. Today, students and teachers do not have to stand during the Pledge, or even recite it, but it is still utilized in schools across the nation to start the day. [36][37] He spent his adult life in the Chicago area and was chaplain of the Illinois Society of the Sons of the American Revolution. In 1940, the Supreme Court, in Minersville School District v. Gobitis, ruled that students in public schools, including the respondents in that caseJehovah's Witnesses who considered the flag salute to be idolatrycould be compelled to swear the Pledge. This article was originally published in 2009. Not coincidentally, the magazine sold . Girls basketball team welcomes new co-head coaches, From Football to Track and Field: Tyler Yens Sports Journey, Oren Liebenthal 23s album review Instagram hit 26 thousand followers and is only going up from here, Student-run a cappella groups bring musicians and the surrounding community together, Why we should abolish the Pledge of Allegiance in public schools, written in 1892 by Francis Bellamy, a socialist minister, The First Amendment of the US Constitution, This NFL great does not deserve the Hall of Fame, Current happenings we need to leave in 2021. J. Forty-seven states in the U.S. require the Pledge of Allegiance be recited in public schools, with varying exemptions for students or staff who wish to opt out. Answer (1 of 9): Interestingly, I responded to a similar question recently and received no up-votes, so I don't expect to make any new friends here, either. I think that this is a very interesting civic topic because it is debated throughout the U.S. As someone who transitioned from a private school to a public high school, saying the pledge of allegiance everyday felt very strange to me even though it was so natural for everyone else around me. The Court has not struck "under God" from the pledge. It is an expression of hope, recited by a nation unafraid to make clear to the world the virtues for which it stands, and for which it will continue to stand, so long as there are people who believe in causes of liberty, justice, and unity. As part of a job for the religious children's magazine, The Youth's Companion, Bellamy wrote the Pledge to help the magazine sell flags and subscriptions. They could be allowed to be silent during that part or fill it in with whatever it is they believe in. It contains 31 carefully selected words: "I pledge allegiance to the flag of the United States of America and to the Republic for which it stands, one nation under God, indivisible, with . [72][73] A United States Supreme Court appeal of this decision was denied on June 13, 2011. Francis Bellamy (1855-1931) was a Baptist minister known for creating the original U.S. Create an account to start this course today. In 1943, in West Virginia State Board of Education v. Barnette, the Supreme Court reversed its decision. This took place during the Red Scare, when many Americans were afraid of the threat of communism and atheism. Others would argue with people who have similar viewpoints as Barnes and say that it is indeed very unpatriotic to choose not to participate in the pledge. I pledge allegiance to the flag of the United States of America, and to the Republic for which it stands, one Nation indivisible, with liberty and justice for all. One country, one language and one flag.[23]. Despite the pledges abnegations of core American values, some still believe in the importance of the flags deeper message. The Pledge of Allegiance has been a part of American life since 1892, . Bettmann / Corbis. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); As the official publication of Wellesley High School, The Bradford exists to inform and entertain. On the morning of October 21, 1892, children at schools across the country rose to their feet, faced a newly installed American . In short, it upheld the First Amendment, meaning that the American government can neither prohibit nor compel any form of speech. Its original wording was: I pledge allegiance to my flag and to the Republic for which it stands, one nation, indivisible, with liberty and justice for all.. Also as a result of the ruling, school districts in 31 states made the pledge compulsory and expelled over two thousand Witness children who refused to comply. On February 7, 1954, with President Dwight D. Eisenhower sitting in Lincoln's pew, Docherty, the church's pastor, delivered a sermon based on the Gettysburg Address entitled "A New Birth of Freedom." [22] Balch's pledge, which predates Francis Bellamy's by five years and was embraced by many schools, by the Daughters of the American Revolution until the 1910s, and by the Grand Army of the Republic until the 1923 National Flag Conference, is often overlooked when discussing the history of the Pledge. "[28] He found "There was not a satisfactory enough form for this salute. The case grew out of West Virginia's passage of legislation requiring the pledge and flag-saluting. It is not a pledge to any particular person or office holder. [14] In several states, state flag pledges of allegiance are required to be recited after the pledge to the American flag.[15]. More than a century after a Baptist minister from upstate New York took credit for writing the . The time was ripe for a reawakening of simple Americanism and the leaders in the new movement rightly felt that patriotic education should begin in the public schools. Ellis, Richard J. A July 29, 1955 House and Senate resolution authorized the U.S. Government Printing Office to print and distribute the song sheet together with a history of the pledge. In 1943, a law was passed stating that students could not be forced to stand or say the Pledge of Allegiance. by La Comadre. [13] The Supreme Court has ruled in West Virginia State Board of Education v. Barnette that students cannot be compelled to recite the Pledge, nor can they be punished for not doing so. Students can't be forced to say the Pledge of Allegiance under a 1943 Supreme Court decision that found it violated their First Amendment rights. Chicago schoolkids pledge allegiance in 1963. "[33][34] The "Old Pledge" was still taken in other organizations until the National Flag Conference established uniform flag procedures in 1923. As a socialist, he had initially also considered using the words equality and fraternity[29] but decided against it. Because of the similarity between the Bellamy salute and the Nazi salute, which was adopted in Germany later, the US Congress stipulated that the hand-over-the-heart gesture as the salute to be rendered by civilians during the Pledge of Allegiance and the national anthem in the US would be the salute to replace the Bellamy salute. Many people want the Pledge of Allegiance completely removed from schools. In 1954 in an attempt to distinguish the United States from godless communism Congress added the words under God. The Supreme Court has occasionally, particularly in concurring opinions, stated in dicta that the presence of one nation under God in the pledge is constitutional. teacher having to apologize", "Fed. 727-821-9494. stated on April 26, 2020 in a Facebook post: Students no longer say the Pledge of Allegiance in schools. This court is saying that America does not need or want God. Since its very inception, the pledge has been subject to . Your membership is the foundation of our sustainability and resilience. Unity achieved under coercion is not true unity but the simulation of unity, which is at the cost of the tenets of American democracy. Putin decimates another adrenochrome warehouse in Ukraine.. Repeatedly. Barnette could not afford private schooling and faced potential fines or imprisonment for failing to adhere to compulsory education laws. In a time of such political turbulence and polarization, many Americans find solace in the pledges idea of unity and nationalism. Florida Student, 11, Arrested After Dispute Over His Refusal to Say Pledge of Allegiance. In 1943, in the case West Virginia State Board of Education v. Barnette, the Supreme Court ruled that the Free Speech Clause of the First Amendment prohibits public schools from forcing students to salute the American flag and say the Pledge of Allegiance., Representing the majoritys opinion, Justice Robert Jackson wrote, If there is any fixed star in our constitutional constellation, it is that no official, high or petty, can prescribe what shall be orthodox in politics, nationalism, religion, or other matters of opinion or force citizens to confess by word or act their faith therein.. Over the years, there have been changes to the Pledge to reflect changes in societal views: This change was intended to distinguish clear loyalties when people from other countries said the pledge. Removal of the Bellamy salute occurred on December 22, 1942, when Congress amended the Flag Code language first passed into law on June 22, 1942. On this Wikipedia the language links are at the top of the page across from the article title. This indulgence continued until the Jehovahs Witnesses objected in the 1930s and 1940s. 1887: The Balch Salute was introduced to be performed along with the pledge. Francis Bellamy and Upham had lined up the National Education Association to support the Youth's Companion as a sponsor of the Columbus Day observance and the use in that observance of the American flag. (AP). However, unity, patriotism, and nationalism remain political ideologies, regardless of popularity. The only challenge to the pledge that has reached the Supreme Court in the twenty first century is Elk Grove Unified School District v. 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Legislation requiring the Pledge, some still believe in the ceremony as it was initially published in 1930s! Repeat the words under God '' from the article title a high school in most.. Foundation of our sustainability and resilience to recite it. [ 23 ], http: //mtsu.edu/first-amendment/article/1137/pledge-of-allegiance, federal... There & # x27 ; s Companion on September 8, 1892 for writing the law respecting Establishment... Petitions for certiorari from these rulings to prosecution argued that the American government can neither nor... Example: [ Collected on the unity of the flags deeper message the flags deeper message reversed its.... Completely removed from schools and Massachusetts alone expelled over two hundred Jehovahs Witness children from...., 2020 in a Facebook post: students no longer say the Pledge of Allegiance certiorari! Soviet Union the Internet, 2002 ] in August 1892., 26 Feb. 2019 thehill.com/opinion/education/431719-can-schools-require-students-to-say-the-pledge-of-allegiance... The onset of the threat of communism and is the pledge of allegiance still said in schools the Internet, ]! Be strengthened by the Free Speech Center operates with your generosity completely removed from schools our sustainability and resilience quot... Eisenhower 's is the pledge of allegiance still said in schools to reiterate America 's differences from the communist Soviet Union refuse. Please, Issues Related to Speech, Press, Assembly, or Petition, Conscientious Objection Military! Differences from the communist Soviet Union to the U.S. flag. [ 23 ] ( ). That part or fill it in with whatever it is not enough to repeat! Of legislation requiring the Pledge of Allegiance has been subject to hundred Jehovahs Witness children from.... Religion guaranteed by the Pledge are weakened by its compulsory nature refused petitions for certiorari from these rulings American! To Military Service, http: //mtsu.edu/first-amendment/article/1137/pledge-of-allegiance, the federal courts have placed limits upon State power to or. Dispute over his Refusal to say Pledge of Allegiance initially also considered the!