anti-war protesters very soon after O'Brien in Tinker v. Des Moines Independent Community School District, which involved public school students who were suspended for wearing black armbands, and Cohen v. California, in which a man was convicted for disturbing the peace by wearing a jacket that read "Fuck the Draft" in a state courthouse. Due in part to increasing domestic opposition, the United States reduced its involvement in Vietnam and completed withdrawal of its forces in 1973; the draft ended the same year. On January 21, 1977, the day after his inauguration, President Jimmy Carter signed Executive Order 11967, which granted a full pardon to anyone who had committed or been convicted of a non-violent violation of the Selective Service Act. This included everyone from draft dodgers to protestors such as O'Brien. The pardon covered all such acts committed between August 4, 1964, the date of the Gulf of Tonkin Incident, and March 28, 1973, the end of American withdrawal. In 1980, however, Congress reinstated the requirement that young men register with the Selective Service System, but without reinstating an active draft. In 1984, the Supreme Court upheld the registration requirement against a claim that it violated the privilege against self-incrimination. The following year, it upheld the conviction of a man who refused to register despite his argument that this refusal constituted a political protest. , male citizens (and many male noncitizen residents) between the ages of 18 to 25 are still required to register for preparation should a military draft be reinstated. The same provision in § 462(b)(3) of the act under which O'Brien was convicted remains law, though destroying draft cards is no longer a common form of protest and recent arrests for that offense are unknown. Subsequent First Amendment decisions For a few years following O'Brien, the decision was primarily cited to by the court for the proposition that an illicit legislative motive would not render a law unconstitutional. Finally, in 1972, the court relied in part on O'Brien to invalidate a law that prohibited picketing outside public schools that was not related to a labor dispute. Quoting O'Brien, the court held that the law "imposes a selective restriction on expressive conduct far 'greater than is essential to the furtherance of [a substantial governmental] interest'". Two years later, the court declared in Spence v. Washington that the O'Brien test was "inapplicable" when the asserted government interest "directly