bloc firmly in control, the Warren Court handed down a series of momentous rulings in the 1960s. Bill of Rights The 1960s marked a major shift in constitutional interpretation, as the Warren Court continued the process of the incorporation of the Bill of Rights in which the provisions of the first ten amendments to the US Constitution were applied to the states. Warren saw the Bill of Rights as a codification of "the natural rights of man" against the government and believed that incorporation would bring the law "into harmony with moral principles." When Warren took office, most of the provisions of the First Amendment already applied to the states, but the vast majority of the Bill of Rights applied only to the federal government. The Warren Court saw the incorporation of the remaining provisions of the First Amendment as well as all or part of the Fourth, Fifth, Sixth, and Eighth Amendments. The Warren Court also handed down numerous other important decisions regarding the Bill of Rights, especially in the field of criminal procedure. In New York Times Co. v. Sullivan, the Supreme Court reversed a libel conviction of the publisher of the New York Times. In the majority opinion, Brennan articulated the actual malice standard for libel against public officials, which has become an enduring part of constitutional law. In Tinker v. Des Moines Independent Community School District, the Court reversed the suspension of an eighth-grade student who wore a black armband in protest of the Vietnam War. Fortas's majority opinion noted that students did not "shed their constitutional rights to freedom of speech or expression at the schoolhouse gate." The Court's holding in United States v. Seeger expanded those who could be classified as conscientious objectors under the Selective Service System by allowing nonreligious individuals with ethical objections to claim conscientious objector status. Another case, United States v. O'Brien, saw the Court uphold a prohibition against burning draft-cards. Warren dissented in Street v. New York in which the Court struck down a state law that prohibited the desecration of the American flag. When his law clerks asked why he dissented in the case, Warren stated, "Boys, it's the American flag. I'm just not going to vote in favor of burning the American flag." In the 1969 case of Brandenburg v. Ohio, the Court held that governments cannot punish speech unless it is "directed to inciting or producing