In the Watts v. Seward School Board case of 1964, the U.S Supreme Court addressed a dispute over racial segregation in public schools in Alaska. The plaintiffs, representing Native Alaskan children, argued that they were being unjustly segregated from white students and demanded integration under the Equal Protection Clause of the Fourteenth Amendment. The school board countered by arguing that separate schooling was necessary due to language barriers and cultural differences between native and non-native students. However, it was found that these reasons did not justify racial segregation as there were no significant educational advantages for either group resulting from separation based on race or national origin. Therefore, this practice violated their constitutional rights to equal protection under law according to Fourteenth Amendment principles established by Brown v Board of Education (1954). Consequently, the court ruled against Seward School Board's policy of segregating Native Alaskan children into separate classes within public schools.

In the dissenting opinion for Watts v. Seward School Board, Justice Black argued that the majority's decision to uphold a state law requiring teachers in private schools to obtain certification from public authorities was an infringement on religious freedom. He contended that this requirement could potentially allow government officials to influence or control religious education, which would be contrary to the First Amendment's protection of free exercise of religion and prohibition against establishment of religion. Furthermore, he believed that such regulation could lead to standardization of ideas taught in schools and thus limit intellectual diversity. In his view, parents should have full authority over their children’s education without interference from state regulations unless there is clear evidence showing harm caused by lack thereof.