board of changes of address, and further preventing fraud or forgery. Third, the registration and raising of troops was unrelated to the suppression of speech. And fourth, the court saw "no alternative means" by which the government could ensure that draft cards would continue to be available than a law that prohibited their willful destruction. Both the government's interest and § 462(b)(3), Warren wrote, "are limited to the noncommunicative aspect of O'Brien's conduct. The governmental interest and the scope of the 1965 Amendment are limited to preventing harm to the smooth and efficient functioning of the Selective Service System. When O'Brien deliberately rendered unavailable his registration certificate, he willfully frustrated this governmental interest. For this noncommunicative impact of his conduct, and for nothing else, he was convicted." Harlan's concurrence Justice John Marshall Harlan II, though joining Warren's opinion, wrote a brief separate concurrence. Harlan wished to extend First Amendment protection to instances in which, though the majority's test was satisfied, the regulation at issue additionally had "the effect of entirely preventing a 'speaker' from reaching a significant audience with whom he could not otherwise lawfully communicate". This was adopted in later cases by the court as an additional prong of the O'Brien test, that the regulation must leave (as phrased in later decisions) "ample alternative channels" of communication. As Harlan felt that O'Brien had other means by which he could communicate his message, he had no problem affirming his conviction. Douglas's dissent Justice William O. Douglas was the sole dissenter. Though he did not express disagreement with the court's First Amendment analysis, he believed that the asserted government interest was only valid when the nation was in a state of war as declared by Congress (which had not been the case since World War II). Douglas questioned whether a peacetime draft was even constitutional, and wanted to reschedule O'Brien for reargument along with two cases challenging the draft that were denied review by the court the same day O'Brien was handed down, even though the parties in O'Brien had not presented arguments or briefs on that issue. Subsequent developments Vietnam War protests and developments in the draft As the Vietnam War became more unpopular, the draft became more of a focal point for opposition and, despite O'Brien, public protests involving the burning of draft cards proliferated. Though the court has not revisited this specific issue, the court ruled for other