In the case of In re Summers (1944), Clyde Summers, a conscientious objector during World War II, was denied admission to the Illinois Bar due to his refusal to take an oath supporting the constitution. The Supreme Court ruled in favor of Summers stating that his religious beliefs and status as a conscientious objector did not disqualify him from practicing law. The court held that denying admission based on these grounds violated his First Amendment rights. It further stated that there is no direct correlation between one's willingness to fight for their country and their ability or integrity as a lawyer. This ruling set precedent for future cases involving freedom of religion and conscience versus professional qualifications.

In the dissenting opinion for In re Summers (1944), Justice Frank Murphy argued that the Illinois Bar Committee's refusal to admit Clyde Summers due to his conscientious objector status was a violation of his constitutional rights. He contended that such an objection does not inherently indicate a lack of good moral character or fitness to practice law, as had been claimed by the majority. Furthermore, he suggested that this decision could set a dangerous precedent where individuals' personal beliefs and principles could unjustly prevent them from practicing their chosen professions. Murphy also pointed out inconsistencies in how different states treated conscientious objectors within their bar associations, indicating potential unfairness and arbitrariness in these decisions. Ultimately, he believed it was essential for legal professionals to be able to hold diverse viewpoints without fear of professional reprisal.