In the case of Follett v. Town of McCormick, 1943, the U.S. Supreme Court ruled that a town could not require a religious book salesman to pay for and obtain a license in order to sell his books door-to-door. The court held that such an ordinance violated the First Amendment's guarantee of freedom of religion and speech as it imposed financial burden on those who wished to spread their religious beliefs through literature distribution. The defendant, Mr. Follett was Jehovah’s Witness who sold books and pamphlets as part of his ministry work but was fined by McCormick for selling without a permit which he couldn't afford due to poverty level income from this activity only . This ruling expanded upon previous decisions protecting free exercise rights by recognizing economic hardship faced by some individuals in practicing their faith.

In the dissenting opinion for Follett v. Town of McCormick, Justice Frankfurter argued that the majority's decision to strike down a licensing fee on religious booksellers was misguided. He contended that such fees were not an infringement on religious freedom but rather a legitimate means for municipalities to raise revenue and regulate commerce. Furthermore, he suggested that exempting religious activities from such fees could lead to unfair advantages or abuses of this privilege. In his view, it was not unreasonable or unconstitutional for towns like McCormick to require all vendors - including those selling religious materials - to pay their fair share towards maintaining public services and infrastructure.