In Prince v. Massachusetts, 321 U.S. 158 (1944) the Court held that the state's child labor laws trumped the parent's right to have her child engage in religious activity in public and the child's independent right to do so. (The case involved the public distribution of the religious magazine Watchtower by the parent and child who were both Jehovah's Witnesses.) Prince stands for the proposition that the state has parens patriae authority over children up to a point. The Supreme Court had upheld the state conviction of a Jehovah's Witness for permitting her niece, a child in her legal custody, to sell publications on the street in violation of state child labor law. 321 U.S. at 159, 64 S. Ct. at 439. The Supreme Court recognized as a cardinal principle "that the custody, care and nurture of the child reside first in the parents," but added: Neither rights of religion nor rights of parenthood are beyond limitation. Acting to guard the general interest in youth's well being, the state as parens patriae may restrict the parent's control by requiring school attendance, regulating or prohibiting the child's labor, and in many other ways. Its authority is not nullified merely because the parent grounds his claim to control the child's course of conduct on religion or conscience. Thus, he cannot claim freedom from compulsory vaccination for the child more than for himself on religious grounds. The right to practice religion freely does not include liberty to expose the community or the child to communicable disease or the latter to ill health or death. . . . The state has a wide range of power for limiting parental freedom and authority in things affecting the child's welfare; and this includes, to some extent, matters of conscience and religious conviction. Id. at 166-67, 64 S. Ct. at 442. The Court concluded: Parents may be free to become martyrs themselves. But it does not follow they are free, in identical circumstances, to make martyrs of their children before they have reached the age of full and legal discretion when they can make that choice for themselves. Id. at 170, 64 S. Ct. at 444.