Has the Supreme Court upheld any state religious tests for public office since 1961?

1. Why Torcaso v. Watkins remains the central precedent and what it actually held

Torcaso v. Watkins ^[6] is presented across multiple summaries as the definitive Supreme Court decision that invalidated state provisions requiring officeholders to affirm belief in God, reasoning that such requirements violate the religion protections of the Constitution. The provided analyses consistently report that the Court concluded a Maryland constitutional provision demanding a declaration of belief in God was unconstitutional, applying the First Amendment’s religion clauses through the Fourteenth Amendment’s protections and effectively barring states from enforcing religious tests for public office. These synopses uniformly treat Torcaso as a durable precedent that prohibits state religious tests, and none of the supplied materials identify a later Supreme Court decision that has upheld any state religious test ^{[1] [7]}.

2. Post‑Torcaso case law: reinforcement rather than reversal, with McDaniel invoked

The supplied analyses note subsequent doctrinal developments as supportive of Torcaso’s core outcome. One analysis explicitly cites McDaniel v. Paty as an example of the Court striking down a state law disqualifying clergy from office, thereby reinforcing the bedrock principle that religious status cannot be used as a qualification or disqualification for public office. The materials emphasize that, rather than retreating from Torcaso, the Court in later cases continued to invalidate statutes that imposed religious criteria on officeholders, demonstrating consistency in the Court’s approach to the religion clauses when applied to state action affecting office qualifications ^[4].

3. How the Court grounds its holding — Article VI, Establishment Clause, and incorporation debates

The summaries reveal two overlapping legal rationales reported by commentators: Torcaso’s outcome is often linked to Article VI’s No Religious Test Clause and to First Amendment Establishment Clause principles applied to the states via the Fourteenth Amendment. Some analyses stress that the Court relied on the Establishment Clause rather than directly on Article VI when extending the prohibition to state governments, yet they treat the result as functionally applying Article VI’s spirit to state officeholding. This divergence in doctrinal emphasis matters for scholars but not for the practical consequence: the Court’s decisions in this area have been interpreted to mean that state religious tests are constitutionally forbidden and the provided materials identify no Supreme Court decision repudiating that conclusion ^{[2] [3] [4]}.

4. The absence of any Supreme Court decision upholding a state religious test since 1961

Across the collected analyses, there is a uniform assertion that the Supreme Court has not upheld any state religious test for public office since Torcaso. The synopses repeatedly state that Torcaso “effectively barred states” from enforcing such tests and that no subsequent Supreme Court case has validated state-imposed religious qualifications. The materials also note the need to monitor future challenges, acknowledging that while the precedent stands, new factual contexts or doctrinal shifts could invite reevaluation; however, based on the supplied sources, the historical record since 1961 contains no instance of the Court upholding a state religious test ^{[1] [7] [5]}.

5. Competing emphases, potential agendas, and unanswered doctrinal questions

The analyses collectively present a consistent factual account but reveal differing emphases that reflect distinct legal agendas: some sources highlight Article VI’s text and federalist implications, while others emphasize First Amendment Establishment Clause doctrine and incorporation through the Fourteenth Amendment. These emphases can signal scholarly or institutional priorities—textualist appeals to Article VI versus structural or incorporation-focused arguments—yet both routes lead to the same practical conclusion reported in the materials. The commentaries also flag remaining doctrinal questions about the precise constitutional hook and invite attention to future litigation that could test boundaries, but no supplied source identifies a Supreme Court decision since 1961 that upholds a state religious qualification for office ^{[3] [8] [4]}.