Pledge of Allegiance

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Official versions
(changes in bold italics)
1892
"I pledge allegiance to my Flag and the republic for which it stands, one nation indivisible, with liberty and justice for all."
1892 to 1922
"I pledge allegiance to my Flag and to the republic for which it stands: one nation indivisible, with liberty and justice for all."
1923
"I pledge allegiance to the Flag of the United States and to the republic for which it stands; one Nation indivisible with liberty and justice for all."
1924 to 1954
"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."
1954 to Present
"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."
 
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Official versions
(changes in bold italics)
1892
"I pledge allegiance to my Flag and the republic for which it stands, one nation indivisible, with liberty and justice for all."
1892 to 1922
"I pledge allegiance to my Flag and to the republic for which it stands: one nation indivisible, with liberty and justice for all."
1923
"I pledge allegiance to the Flag of the United States and to the republic for which it stands; one Nation indivisible with liberty and justice for all."
1924 to 1954
"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."
1954 to Present
"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 Pledge of Allegiance of the United States is an expression of fealty to the federal flag and the republic of the United States of America, originally composed by Francis Bellamy in 1892 and formally adopted by Congress as the pledge in 1942.[1] The official name of The Pledge of Allegiance was adopted in 1945. The last change in language came on Flag Day 1954 when the words "under God" were added.[2]

Congressional sessions open with the recital of the Pledge, as do many government meetings at local levels, and meetings held by many private organizations. It is also commonly recited in school at the beginning of every school day, although the Supreme Court has ruled on several occasions that students cannot be compelled to recite the Pledge, nor can they be punished for not doing so.

According to the United States Flag Code, the Pledge of Allegiance reads:[3]

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.

According to the Flag Code, the Pledge "should be rendered by standing at attention facing the flag with the right hand over the heart. When not in uniform, men should remove any non-religious headdress with their right hand and hold it at the left shoulder, the hand being over the heart. Persons in uniform should remain silent, face the flag, and render the military salute."[3]

Origins[edit]

The Pledge of Allegiance was written in August 1892 by Francis Bellamy (1855–1931), who was a Baptist minister, a Christian socialist,[4][5] and the cousin of socialist utopian novelist Edward Bellamy (1850–1898). The original "Pledge of Allegiance" was published in the September 8 issue of the popular children's magazine The Youth's Companion as part of the National Public-School Celebration of Columbus Day, a celebration of the 400th anniversary of Christopher Columbus's arrival in the Americas. The event was conceived and promoted by James B. Upham, a marketer for the magazine, as a campaign to instill the idea of American nationalism by selling flags to public schools and magazines to students.[6] According to author Margarette S. Miller this was in line with Upham's vision which he "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.'"[7]

Bellamy's original Pledge read as follows:[8][9]

I pledge allegiance to my Flag and the Republic for which it stands, one nation indivisible, with liberty and justice for all.
Students swearing the Pledge on Flag Day in 1899

The Pledge was supposed to be quick and to the point. Bellamy designed it to be recited in 15 seconds. As a socialist, he had initially also considered using the words equality and fraternity[6] but decided against it – knowing that the state superintendents of education on his committee were against equality for women and African Americans.[10]

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 along with the use of the American flag. 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 (this was issued as Presidential Proclamation 335). Subsequently, the Pledge was first used in public schools on October 12, 1892, during Columbus Day observances organized to coincide with the opening of the World's Columbian Exposition in Chicago, Illinois.[11]

Bellamy's account[edit]

In Francis Bellamy's recollection of the creation of the Pledge, he recalled "At the beginning of the nineties patriotism and national feeling was at a low ebb. The patriotic ardor of the Civil War was an old story ... 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."[12] James Upham "felt that a flag should be on every schoolhouse",[12] so the publication "fostered a plan of selling flags to schools through the children themselves at cost, which was so successful that 25,000 schools acquired flags in 1 year."[12]

As the World's Columbian Exposition, a.k.a. Chicago World's Fair, was set to celebrate the 400th anniversary the arrival of Christopher Columbus in the Americas, Upham sought to link the publication's drive to the event, "so that every school in the land ... would have a flag raising, under the most impressive conditions."[12] Bellamy was placed in charge of this operation and was soon lobbying "not only the superintendents of education in all the States, but also worked with governors, Congressmen, and even the President of the United States."[12] 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."[12] Bellamy recalled that the event "had to be more than a list of exercises. The ritual must be prepared with simplicity and dignity."[12]

Edna Dean Proctor wrote an ode for the event and "There was also an oration suitable for declamation."[12] Bellamy held "Of course, the nub of the program was to be the raising of the flag, with a salute to the flag recited by the pupils in unison."[12] He found "There was not a satisfactory enough form for this salute. The Balch salute which ran 'I give my heart and my hand to my country, one country, one language, one flag.' seemed too juvenile and lacking in dignity."[12] 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. I especially stressed the word 'allegiance.' ... Beginning with the new word allegiance, I first decided that 'pledge' was a better school word than 'vow' or 'swear'; and that the first person singular should be used, and that 'my' flag was preferable to 'the.'"[12] Bellamy considered the words "country, nation, or Republic", choosing the last as "it distinguished the form of government chosen by the founding fathers and established by the Revolution. The true reason for allegiance to the flag is the Republic for which it stands."[12] Bellamy then reflected on the sayings of Revolutionary and Civil War figures, and concluded "all that pictured struggle reduced itself to three words, one Nation indivisible."[12]

Bellamy considered the slogan of the French Revolution, Liberté, égalité, fraternité ("liberty, equality, fraternity"), but held that "fraternity was too remote of realization, and as equality was a dubious word."[12] Concluding "Liberty and justice were surely basic, were undebatable, and were all that any one Nation could handle. If they were exercised for all they involved the spirit of equality and fraternity."[12]

After being reviewed by Upham and other members of The Youth's Companion, the Pledge was approved and put in the official Columbus Day program. Bellamy noted that, "In later years the words 'to my flag' were changed to 'to the flag of the United States of America' because of the large number of foreign children in the schools."[12] Bellamy disliked the change, as "it did injure the rhythmic balance of the original composition."[12]

Changes[edit]

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 United States. The words "of America" were added a year later. The United States Congress officially recognized the Pledge for the first time, in the following form, on June 22, 1942:

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.

Addition of "under God"[edit]

Louis A. Bowman, an attorney from Illinois, was the first to initiate the addition of "under God" to the Pledge. The National Society of the Daughters of the American Revolution gave him an Award of Merit as the originator of this idea.[13][14] He spent his adult life in the Chicago area and was Chaplain of the Illinois Society of the Sons of the American Revolution. At a meeting on February 12, 1948,[13] Lincoln's Birthday, he led the Society in swearing the Pledge with two words added, "under God." He stated that the words came from Lincoln's Gettysburg Address. Though not all manuscript versions of the Gettysburg Address contain the words "under God", all the reporters' transcripts of the speech as delivered do, as perhaps Lincoln may have deviated from his prepared text and inserted the phrase when he said "that the nation shall, under God, have a new birth of freedom." Bowman repeated his revised version of the Pledge at other meetings.[13]

In 1951, the Knights of Columbus, the world's largest Catholic fraternal service organization, also began including the words "under God" in the Pledge of Allegiance.[15] In New York City, on April 30, 1951, the Board of Directors of the Knights of Columbus adopted a resolution to amend the text of their Pledge of Allegiance at the opening of each of the meetings of the 800 Fourth Degree Assemblies of the Knights of Columbus by addition of the words "under God" after the words "one nation." Over the next two years, the idea spread throughout Knights of Columbus organizations nationwide. On August 21, 1952, the Supreme Council of the Knights of Columbus at its annual meeting adopted a resolution urging that the change be made universal and copies of this resolution were sent to the President, the Vice President (as Presiding Officer of the Senate) and the Speaker of the House of Representatives. 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. Several State Fraternal Congresses acted likewise almost immediately thereafter. This campaign led to several official attempts to prompt Congress to adopt the Knights of Columbus’ policy for the entire nation. These attempts were eventually a success.[16]

In 1952, Susan Anald wrote a letter to President Truman suggesting the inclusion of "under God" in the Pledge of Allegiance. Mr. Langmack was a Danish philosopher and educator who came to the United States in 1911. He was one of the originators of the Prayer Breakfast and a religious leader in Washington, D.C. President Truman met with him along with several others to discuss the inclusion of "under God" just before "with liberty and justice".[citation needed]

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.

Rev. Dr. George MacPherson Docherty (left) and President Eisenhower (second from left) on the morning of February 7, 1954, at the New York Avenue Presbyterian Church

Prior to February 1954, no endeavor to get the Pledge officially amended succeeded. The final successful push came from George MacPherson Docherty. Some American presidents honored Lincoln's birthday by attending services at the church Lincoln attended, New York Avenue Presbyterian Church by sitting in Lincoln's pew on the Sunday nearest February 12. On February 7, 1954, with President Eisenhower sitting in Lincoln's pew, the church's pastor, George MacPherson Docherty, delivered a sermon based on the Gettysburg Address titled "A New Birth of Freedom." He argued that the nation's might lay not in arms but its spirit and higher purpose. He noted that the Pledge's sentiments could be those of any nation, that "there was something missing in the pledge, and that which was missing was the characteristic and definitive factor in the American way of life." He cited Lincoln's words "under God" as defining words that set the United States apart from other nations.

President Eisenhower had been baptized a Presbyterian very recently, just a year before. He responded enthusiastically to Docherty in a conversation following the service. Eisenhower acted on his suggestion the next day and on February 8, 1954, Rep. Charles Oakman (R-Mich.), introduced a bill to that effect. Congress passed the necessary legislation and Eisenhower signed the bill into law on Flag Day, June 14, 1954.[17] Eisenhower stated "From this day forward, the millions of our school children will daily proclaim in every city and town, every village and rural school house, the dedication of our nation and our people to the Almighty.... In this way we are reaffirming the transcendence of religious faith in America's heritage and future; in this way we shall constantly strengthen those spiritual weapons which forever will be our country's most powerful resource, in peace or in war."[18]

The phrase "under God" was incorporated into the Pledge of Allegiance June 14, 1954, by a Joint Resolution of Congress amending §4 of the Flag Code enacted in 1942.[17]

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.[16]

Salute[edit]

Students pledging to the flag with the Bellamy salute circa 1941.

Swearing of the Pledge is accompanied by a salute. An early version of the salute, adopted in 1892, was known as the Bellamy salute. It started with the hand outstretched toward the flag, palm down, and ended with the palm up. Because of the similarity between the Bellamy salute and the Nazi salute, developed later, the United States Congress instituted 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 United States, instead of the Bellamy salute. 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.[19]

Controversy[edit]

In 1940 the Supreme Court, in Minersville School District v. Gobitis, ruled that students in public schools, including the respondents in that case, Jehovah's Witnesses who considered the flag salute to be idolatry, could be compelled to swear the Pledge. A rash of mob violence and intimidation against Jehovah's Witnesses followed the ruling. In 1943 in West Virginia State Board of Education v. Barnette the Supreme Court reversed its decision. Justice Robert H. Jackson writing for the 6 to 3 majority went beyond ruling that public school students are not required to say the Pledge on narrow grounds, but asserted in clarion words how such ideological dogma is antithetical to the principles of the country, concluding with:

"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. If there are any circumstances which permit an exception, they do not now occur to us."

In a later case, the 11th Circuit Court of Appeals held that students are also not required to stand for the Pledge.[20]

First graders of Japanese ancestry pledging allegiance to the American flag (photo by Dorothea Lange)

Requiring or promoting of the Pledge on the part of the government has drawn criticism and legal challenges on several grounds.

One objection[21] states that a democratic republic built on freedom of dissent should not require its citizens to pledge allegiance to it, and that the First Amendment to the United States Constitution protects one's right to refrain from speaking or standing (also a form of speech).[20] Another objection lies in the fact that the people who are most likely to recite the Pledge every day, small children in schools, cannot really give their consent or even completely understand the Pledge they are taking.[22]

Many objections have been raised since the addition of the phrase "under God" to the Pledge in 1954. Critics[23] contend that a government requiring or promoting this phrase violates protections against the establishment of religion guaranteed in the Establishment Clause of the First Amendment.

In 2004, linguist Geoffrey Nunberg criticized the addition of "under God" for a different reason. The original supporters of the addition thought that they were simply quoting Lincoln's Gettysburg Address. However, Nunberg said that to Lincoln and his contemporaries, "under God" meant "God willing" and they would have found its use in the Pledge of Allegiance ungrammatical.[24][25]

The introduction of "under God" in the 1950s was done during the Cold War, as a way to differentiate the U.S. from the concept of communist state atheism.[26][27]

Legal challenges[edit]

Prominent legal challenges in the 1950s were brought by the Jehovah's Witnesses, a group whose beliefs preclude swearing loyalty to any power other than God,[28] and who objected to policies in public schools requiring students to swear an oath to the flag. They objected on the grounds that their rights to freedom of religion as guaranteed by the Free Exercise Clause of the First Amendment were being violated by such requirements. First case was in 1935, when two children, Lillian and William Gobitis, ages ten and twelve, were expelled from the Minersville, Pennsylvania public schools in 1935 for failing to salute the flag and recite the Pledge of Allegiance.[29][30]

In a 2002 case brought by atheist Michael Newdow, whose daughter was being taught the Pledge in school, the Ninth Circuit Court of Appeals ruled the phrase "under God" an unconstitutional endorsement of monotheism when the Pledge was promoted in public school. In 2004, the Supreme Court heard Elk Grove Unified School District v. Newdow, an appeal of the ruling, and rejected Newdow's claim on the grounds that he was not the custodial parent, and therefore lacked standing, thus avoiding ruling on the merits of whether the phrase was constitutional in a school-sponsored recitation. 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. On September 14, 2005, District Court Judge Lawrence Karlton ruled in their favor. Citing the precedent of the 2002 ruling by the Ninth Circuit Court of Appeals, Judge Karlton issued an Order stating that, upon proper motion, he would enjoin the school district defendants from continuing their practices of leading children in pledging allegiance to "one Nation under God".[31]

A bill, H.R. 2389, was introduced in Congress in 2005 which, if enacted into law, would have stripped the Supreme Court and most federal courts of the power to consider any legal challenges to government requiring or promoting of the Pledge of Allegiance. H.R. 2389 was passed by the House of Representatives in July 2006, but failed after the Senate did not take up the bill. This action is viewed in general as court stripping by Congress over the Judiciary. Even if a similar bill is enacted, its practical effect may not be clear: proponents of the bill have argued that it is a valid exercise of Congress's power to regulate the jurisdiction of the federal courts under Article III, Section 2 of the Constitution, but opponents question whether Congress has the authority to prevent the Supreme Court from hearing claims based on the Bill of Rights (since amendments postdate the original text of the Constitution and may thus implicitly limit the scope of Article III, Section 2). Judges and legal analysts have voiced concerns that Congress can strip or remove from the judicial branch the ability to determine if legislation is constitutional.[32]

Mark J. Pelavin, former Associate Director of the Religious Action Center of Reform Judaism,[33] objected to court stripping in regards to the Pledge of Allegiance, "Today's House adoption of the so-called "Pledge Protection Act" is a shameful effort to strip our federal courts of their ability to uphold the rights of all Americans. By removing the jurisdiction of federal courts, including the Supreme Court, from cases involving the Pledge, this legislation sets a dangerous precedent: threatening religious liberty, compromising the vital system of checks and balances upon which our government was founded, and granting Congress the authority to strip the courts' jurisdiction on any issue it wishes. Today, the issue was the Pledge of Allegiance, but tomorrow it could be reproductive rights, civil rights, or any other fundamental concern."[34]

In 2006, in the Florida case Frazier v. Alexandre, a federal district court in Florida ruled that a 1942 state law requiring students to stand and recite the Pledge of Allegiance violates the First and Fourteenth Amendments of the U.S. Constitution.[35] As a result of that decision, a Florida school district was ordered to pay $32,500 to a student who chose not to say the pledge and was ridiculed and called "unpatriotic" by a teacher.[36]

In 2009, a Montgomery County, Maryland, teacher berated and had school police remove a 13-year-old girl who refused to say the Pledge of Allegiance in the classroom. The student's mother, assisted by the American Civil Liberties Union of Maryland, sought and received an apology from the teacher, as state law and the school's student handbook both prohibit students from being forced to recite the Pledge.[37]

On March 11, 2010, the United States Court of Appeals for the Ninth Circuit upheld the words "under God" in the Pledge of Allegiance in the case of Newdow v. Rio Linda Union School District.[38][39] In a 2–1 decision, the appellate court ruled that the words were of a "ceremonial and patriotic nature" and did not constitute an establishment of religion.[38] Judge Stephen Reinhardt dissented, writing that "the state-directed, teacher-led daily recitation in public schools of the amended 'under God' version of the Pledge of Allegiance... violates the Establishment Clause of the Constitution."[40]

On November 12, 2010, in a unanimous decision,[41] the United States Court of Appeals for the First Circuit in Boston affirmed a ruling by a New Hampshire lower federal court which found that the pledge's reference to God does not violate non-pledging students' rights if student participation in the pledge is voluntary.[42] A United States Supreme Court appeal of this decision was denied on June 13, 2011.[43][44]

All states except five (Hawaii, Iowa, Oklahoma, Vermont and Wyoming) give time for the pledge to be recited as part of the school day.[45] Although 45 states expressly give time for the pledge, it is still at the discretion of the local school board and/or the individual teacher.

In September 2013, a case was brought before the Massachusetts Supreme Judicial Court arguing that the pledge violates the Equal Rights Amendment of the Constitution of Massachusetts.[46]

See also[edit]

Notes[edit]

  1. ^ "Society & Community. Faith in America: The Legal Dilemma". NOW with Bill Moyers. PBS. June 29, 2002. 
  2. ^ "The Pledge of Allegiance and Our Flag of the United States". Their History and Meaning. Archived from the original on 2006-09-23. Retrieved 2014-01-08. 
  3. ^ a b "Title 4, Chapter 1, Section 4, US Code". Archived from the original on 2004-09-24. Retrieved 2012-01-16. 
  4. ^ Kubal, Timothy (October 2008). Cultural Movements and Collective Memory : Christopher Columbus and the Rewriting of the National Origin Myth. Basingstoke, Hampshire, GBR: Palgrave Macmillan. ISBN 9780230615762. 
  5. ^ "Grand Lodge of BC and Yukon profile of Bellamy". Freemasonry.bcy.ca. Retrieved 2013-10-23. 
  6. ^ a b Bellamy, Francis, "The Story of the Pledge of Allegiance to the Flag", University of Rochester Library Bulletin, Vol. VIII, Winter 1953.
  7. ^ Margarette S. Miller (1946). I Pledge Allegiance. Christopher Publishing House, Youth's companion. 
  8. ^ Francis Bellamy - The word "to" was inserted between "...my Flag and" and "the Republic" in October 1892.
  9. ^ "The Pledge of Allegiance". Historic Documents. Independence Hall Association: ushistory.org. Retrieved 29 August 2012. 
  10. ^ Dr. John W. Baer. "The Pledge of Allegiance A Short History". 
  11. ^ Miller, Margarette S. (1976). Twenty Three Words: A Biography of Francis Bellamy: Author of the Pledge of Allegiance. Portsmouth, Vir.: Printcraft Press. pp. 63-65 ISBN 0686156269
  12. ^ a b c d e f g h i j k l m n o p q Frances Bellamy. A Brief Synopsis of the Story of the Origin of the Pledge taken from the Detailed Narrative by Frances Bellamy, Author of the Pledge. Congressional Record 91 Cong. Rec. (1945) House. pp. 5510–5511. 
  13. ^ a b c Baer, John W. (2007). The Pledge of Allegiance: A Revised History and Analysis, 1892-2007. Annapolis, MD: Free State Press. 
  14. ^ Merriman, Scott A. (2007). Religion and the Law in America: An Encyclopedia of Personal Belief. ABC-CLIO. ISBN 978-1-85109-863-7. 
  15. ^ "Knights of Columbus Fact Sheet". Knights of Columbus. Retrieved 2011-06-16. 
  16. ^ a b "How the words "UNDER GOD" came to be added to the Pledge of Allegiance to the Flag". Retrieved 2013-10-23. 
  17. ^ a b Pub.L. 83-396, Chap. 297, 68 Stat. 249, H.J.Res. 243, enacted June 14, 1954.
  18. ^ "God In America: God in the White House". PBS. 
  19. ^ Leepson, Marc (2006). Flag: An American Biography. Macmillan. p. 171. ISBN 0-312-32309-3. 
  20. ^ a b Holloman ex rel. Holloman v. Harland, 370 F.3d 1252 (11th Cir. 2004).
  21. ^ Lane v. Owens; 03-B-1544, United States District Court, District of Colorado
  22. ^ Olander, Herbert T. (December 1941). "Children's Knowledge of the Flag Salute". The Journal of Educational Research 35 (4): 300–305. 
  23. ^ "Court upholds 'under God' in Pledge of Allegiance". Associated Press. 2010-03-11. Retrieved 2010-03-11. 
  24. ^ Geoffrey Nunberg (2004-06-20). "I Might Have Guessed Parson Weems Would Figure In There Somewhere". Language Log. Retrieved 2007-05-03. 
  25. ^ Geoffrey Nunberg (2004-06-20). ""(Next) Under God," Phrasal Idiom". Language Log. Retrieved 2007-05-03. 
  26. ^ Merriman, Scott A. (2007). Religion and the Law in America: An Encyclopedia of Personal Belief. ABC-CLIO. p. 111. ISBN 978-1-85109-863-7. 
  27. ^ Nunberg, Geoff. I Pledge Allegiance To Linguistic Obfuscation. npr.org. Retrieved 12 Aug. 2012.
  28. ^ Jehovah's Witnesses-Proclaimers of God's Kingdom, Watchtower Bible and Tract Society of New York, 1993, pp. 196-197
  29. ^ "Flag Salute Cases". The Free Dictionary. Retrieved 2014-02-03. 
  30. ^ Minersville School District v. Gobitis, 310 U.S. 586, 60 S. Ct. 1010, 84 L. Ed. 1375 (1940)
  31. ^ David Kravets (September 16, 2005), Federal judge rules Pledge of Allegiance is unconstitutional, archived from the original on 2006-01-11, retrieved 2008-03-31 
  32. ^ "Retired Federal Judges Urge Congress Not to Pass "Court-Stripping" Measure that Would Deny Rights in". Brennancenter.org. 2005-12-08. Retrieved 2012-01-16. 
  33. ^ URJ Biographical Page for Mark Pelavin
  34. ^ "Court-stripping and Legislating Against the First Amendment (12 July 2006)". Jewsonfirst.org. Retrieved 2012-01-16. 
  35. ^ Frazier v. Alexandre, 434 F.Supp.2d 1350 (S.D. Fla. May 31, 2006).
  36. ^ "Frazier v. Alexandre, No. 05-81142 (S.D. Fla. May 31, 2006)". National School Boards Association. March 15, 2011. Archived from the original on 2011-03-15. 
  37. ^ Johnson, Jenna (February 24, 2010). "Pledge of Allegiance dispute results in Md. teacher having to apologize". The Washington Post. Retrieved February 25, 2010. 
  38. ^ a b Chea, Terence (March 12, 2010). "Fed. appeals court upholds 'under God' in pledge". Associated Press. Archived from the original on 2010-03-15. Retrieved March 12, 2010. 
  39. ^ Newdow vs. Rio Linda Union School District (9th Cir. Mar 12, 2010). Text
  40. ^ "Pledge of Allegiance's God reference now upheld by court". LA Times. March 12, 2010. Retrieved January 11, 2011. 
  41. ^ Freedom from Religion Foundation v. Hanover School District (1st Cir. Nov 12, 2010). Text
  42. ^ Lavoie, Denise (November 15, 2010). "Court OKs NH law allowing 'God' pledge in schools". Boston Globe (Boston, MA: Christopher M. Mayer). Retrieved November 16, 2010. "The constitutionality of a New Hampshire law..." 
  43. ^ Egelko, Bob (June 15, 2011). "High court spurns atheist's 'under God' challenge". San Francisco Chronicle (San Francisco, CA: Hearst Corporation). "A Sacramento atheist's challenge to the addition of "under God" to the Pledge of Allegiance..." 
  44. ^ Supreme Court of the United States (June 13, 2011). "Freedom From Religion Foundation, Petitioner v. United States, et al.". Supreme Court of the United States. Retrieved June 15, 2011. 
  45. ^ Goss, Crystal (August 13, 2012). "Pledge of Allegiance in Schools: Not Required in These 5 States". 
  46. ^ "'Under God' part of Pledge of Allegiance under review in Massachusetts". CNN.com. 2013-09-04. Retrieved 2013-10-23. 

References[edit]