Loyalty oaths have long been imposed upon citizens of both monarchies and republics as conditions precedent to the granting of certain governmental favors or to the withholding of certain punishments. But whether the oath is taken to gain a benefit or to avoid a criminal sanction, the aftermath of refusing to take a loyalty oath is that the citizen is penalized. This is not to suggest that a loyalty oath is dangerous per se, although some Justices of the United States Supreme Court have taken this view., Certainly a governmental body should not be denied the power to protect itself from those who would destroy it; nor should it be denied the right to withhold benefits from those who would use them against the government.