In the case of Prince v. Massachusetts, the U.S. Supreme Court ruled in 1943 that child labor laws could be applied to religious activities. The case involved a Jehovah's Witness who was convicted for violating child labor laws by allowing her nine-year-old niece to sell religious magazines on the streets of Boston. She argued that this violated her First Amendment rights to free exercise of religion and freedom of speech, as well as her Fourteenth Amendment right to parental liberty. However, the court upheld her conviction with a 5-4 majority vote stating that while these freedoms are important, they do not include complete liberty for parents or guardians over children’s lives and welfare; thus states have broad authority in regulating actions related to children’s health and safety even if those actions are tied with religious conduct.

In the dissenting opinion for Prince v. Massachusetts, Justice Rutledge argued that the state's child labor laws infringed upon religious freedoms protected by the First Amendment. He contended that Sarah Prince was exercising her Jehovah’s Witness faith when she allowed her niece to distribute religious literature on public streets, and thus should be exempt from such regulations. While he acknowledged a state's right to protect children from exploitation or harm, he believed this case did not involve any form of abuse or neglect but rather an act of faith in accordance with their religion. Therefore, applying child labor laws in this context was inappropriate and unconstitutional as it violated freedom of religion without sufficient justification.