In "The New York Times Co. v. Sullivan", the Supreme Court reversed a libel conviction of the publisher of "The New York Times". In the majority opinion, Brennan articulated the actual malice standard for libel against public officials, which has become an enduring part of constitutional law. In "Tinker v. Des Moines Independent Community School District", the Court reversed the suspension of an eighth-grade student who wore a black armband in protest of the Vietnam War. Fortas's majority opinion noted that students did not "shed their constitutional rights to freedom of speech or expression at the schoolhouse gate." The Court's holding in "United States v. Seeger" expanded those who could be classified as conscientious objectors under the Selective Service System by allowing nonreligious individuals with ethical objections to claim conscientious objector status. Another case, "United States v. O'Brien", saw the Court uphold a prohibition against burning draft-cards. Warren dissented in "Street v. New York" in which the Court struck down a state law that prohibited the desecration of the American flag. When his law clerks asked why he dissented in the case, Warren stated, "Boys, it's the American flag. I'm just not going to vote in favor of burning the American flag." In the 1969 case of "Brandenburg v. Ohio", the Court held that governments cannot punish speech unless it is "directed to inciting or producing imminent lawless action and is likely to incite or produce such action."