In the case of United States v. Zazove, 1947, the Supreme Court examined whether a federal court could exercise jurisdiction over an individual who had been drafted into military service but refused to report for duty on religious grounds. The defendant, Philip Zazove, was a member of Jehovah's Witnesses and claimed that his faith prohibited him from participating in war or any form of military service. He argued that he should be exempted from conscription under Section 5(g) of the Selective Training and Service Act which provided exemptions for individuals whose religious beliefs opposed participation in war. The government contended that since Mr. Zazove did not belong to a "well-recognized" religious sect or organization as required by law at the time, he was not entitled to exemption based on his personal beliefs alone. The Supreme Court ruled against Mr. Zazove stating that while freedom of religion is protected under First Amendment rights; however it does not grant absolute immunity from laws applicable to all citizens including compulsory military service during wartime. This ruling affirmed lower courts' decisions upholding draft laws despite individual claims about their constitutionality based on personal interpretations of religion rather than established doctrines recognized by organized religions.

The dissenting opinion in the United States v. Zazove case argued that the majority's decision to uphold a lower court ruling, which denied citizenship to an individual who refused military service on religious grounds during peacetime, was incorrect. The dissent contended that such refusal did not demonstrate lack of attachment to the principles of the Constitution or disloyalty to America as required by naturalization law for denial of citizenship. It emphasized that freedom of religion is one such principle enshrined in the First Amendment and should be respected even when it leads individuals towards pacifism. Furthermore, they noted that Congress had recognized conscientious objection as valid during wartime drafts and thus it seemed inconsistent not to do so during peacetime when considering applications for citizenship.