te overtook the decision in the "Flag Salute"
Case.[53] In May, 1943, the Court found that an ordinance of the city of
Struthers, Ohio, which made it unlawful for anyone distributing
literature to ring a doorbell or otherwise summon the dwellers of a
residence to the door to receive such literature, was violative of the
Constitution when applied to distributors of leaflets advertising a
religious meeting.[54] But eight months later it sustained the
application of Massachusetts' child labor laws in the case of a nine
year old girl who was permitted by her legal custodian to engage in
"preaching work" and the sale of religious publications after hours.[55]
However, in Saia _v._ New York[56] decided in 1948, the Court held, by a
vote of five Justices to four, that an ordinance of the city of
Lockport, New York, which forbade the use of sound amplification devices
except with the permission of the Chief of Police was unconstitutional
as applied in the case of a Jehovah's Witness who used sound equipment
to amplify lectures in a public park on Sunday, on religious subjects.
But a few months later the same Court, again dividing five-to-four,
sustained a Trenton, New Jersey ordinance which banned from that city's
streets all loud speakers and other devices which emit "loud and raucous
noises."[57] The latest state of the doctrine on this particular topic
is represented by three cases, all decided the same day. In one the
conviction of a Baptist minister for conducting religious services in
the streets of New York City without first obtaining a permit from the
city police commissioner was overturned,[58] a permit having been
refused him on the ground that he had in the past ridiculed other
religious beliefs thereby stirring strife and threatening violence.
Justice Jackson dissented, quoting Mr. Bertrand Russell to prove that
"too little liberty brings stagnation, and too much brings chaos. The
fever of our times," he suggested, "inclines the Court today to favor
chaos."[59] In the second, the Court upset the conviction of a group of
Jehovah's Witnesses in Maryland for using a public park without first
obtaining a permit.[60] The third case,[61] which had nothing to do with
religion, affords an interesting foil to the other two. It is dealt with
in another connection.[62]

FREE EXERCISE OF RELIGION: OBLIGATIONS OF CITIZENSHIP

In 1918 the Court rejected as too unsound to require more than a mere
statement the argument that th