Religious requirements for political office in the United States were unconstitutional on the national level of the federal system of government established by the Constitution of the United States since the ratification of the articles of the Constitution in 1788. The No Religious Test Clause of Article VI of the Constitution expressly stated that "no religious test shall ever be required as a qualification to any office or public trust under the United States". Additionally, the Establishment Clause of the First Amendment of the United States Constitution, explicitly prohibiting the Congress of the United States from making any law "respecting an establishment of religion", was ratified as part of the Bill of Rights only a few years later. Neither protected the civil rights safeguarded by the Constitution from the authorities of the individual states of the United States, as the Constitution was only deemed to apply to the central government of the country. The state governments were therefore able to legally exclude persons from holding public offices on religious grounds. As a result of the incorporation of the Bill of Rights after the American Civil War, the protections of the Bill of Rights were extended to the individual states on the basis of the Due Process Clause of the Fourteenth Amendment to the Constitution. State requirements for political office were not entirely abolished until 1961, when the Supreme Court of the United States rejected a provision of the Maryland State Constitution requiring all public officeholders to declare a belief in God in the case of Torcaso v. Watkins. Roy Torcaso, an atheist, had filed suit in Maryland to establish his right to become a notary public without swearing his belief in God, as demanded by the Maryland Constitution. After being rebuffed, Torcaso went to the Supreme Court, which ruled unanimously that the state's religious restriction was invalid as a violation of guaranteed constitutional rights. Although the Torcaso decision dismissed enforcement of religious requirements for office as unconstitutional in the United States, antiquated provisions barring atheists from occupying political offices were not immediately stricken from state legislation. As a result, a number of lawsuits were initiated after 1961 to secure the right to hold public office without conforming to religious requirements. These cases followed the United States Supreme Court's precedent. In 1997, the Supreme Court of South Carolina decided the case of Silverman v. Campbell, likewise following the Supreme Court ruling in Torcaso v. Watkins. The court held that Article VI, section 2 of the South Carolina State Constitution and Article XVII, section 4 could not be enforced as articles in conflict with the Constitution of the United States.