South Carolina—where a Protestant denomination was the established state religion—introduced the clause to Article VI, and it passed with little opposition. Forced oaths The Supreme Court has interpreted this provision broadly, saying that any required oath to serve anything other than the Constitution is invalid. In the case of Ex parte Garland, the Court overturned a loyalty oath that the government had tried to apply to pardoned Confederate officials. As the officials had already received full presidential pardons (negating an argument based on their potential status as criminals), the Court ruled that forcing officials and judges to swear loyalty oaths was unconstitutional. State law Earlier in U.S. history, the doctrine of states' rights allowed individual states complete discretion regarding the inclusion of a religious test in their state constitutions. In 1961 such religious tests by the states were deemed to be unconstitutional by the extension of the First Amendment provisions to the states (via the incorporation of the 14th Amendment). In the 1961 case Torcaso v. Watkins, the U.S. Supreme Court unanimously ruled that such language in state constitutions was in violation of the First and Fourteenth Amendments to the United States Constitution. Citing the Supreme Court's interpretation of the Establishment Clause in Everson v. Board of Education and linking it to Torcaso v. Watkins, Justice Hugo Black stated for the Court: We repeat and again reaffirm that neither a State nor the Federal Government can constitutionally force a person "to profess a belief or disbelief in any religion." Neither can constitutionally pass laws or impose requirements which aid all religions as against non-believers, and neither can aid those religions based on a belief in the existence of God as against those religions founded on different beliefs. The Supreme Court did not rule on the applicability of Article VI, stating that "Because we are reversing the judgment on other grounds, we find it unnecessary to consider appellant's contention that this provision applies to state as well as federal offices." Eight states include language in their constitutions either requiring state officeholders to have particular religious beliefs or specifically protecting those who do. However, the requirements are unenforceable because of the 1961 Supreme Court decision. The states are: Arkansas (Article 19 Section 1) Maryland (Declaration of Rights, Article 37) Mississippi (Article 14, Section 265) North Carolina (Article 6 Section 8) Pennsylvania (Article 1 Section 4)Specifically protects officeholders with religious belief but is