The applicant. said the Court. had to meet the law on its terms. Another case. decided on the same day as the Macintosh case. was that of the United States against Bland. In the Bland case. naturalization was denied to a woman applicant. a native of Canada. who had spent 9 months in France in World War I as a United States Army nurse. She had refused to take the oath as written and had requested that she be allowed to insert into the naturalization oath "as far as my Christian conscience will allow." The Bland case was the only case of the three which presented the case of an actual noncombatant who. despite her service. was denied naturalization. These three decisions were the judicial interpretations of the law until 1946 when the Girouard case was decided by the Supreme Court. Prior to the Girouard case in 1946 it was the settled law that the oath of allegiance included by implication a promise to bear arms. and that a refusal so to do was also indicative of nonattachment to the principles of the Constitution.
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naturalization