Bookstein held that "the child of a nonbeliever may simply omit the words, 'under God', in reciting the pledge. His 'non-conformity', if such it be, will not, in the circumstances of this case, set him apart from his fellow students or bring 'pressure' to bear in any real sense." Bookstein again cited "Zorach v. Clauson" holding that to side with Lewis' claims against the government would be preferring those who believe in no religion over those who do not'. The First Amendment does not require this."