 The Bancroft Treaties—a series of agreements between the United States and other nations which had sought to limit dual citizenship following naturalization—were eventually abandoned after the Carter administration concluded that "Afroyim" and other Supreme Court decisions had rendered them unenforceable.The impact of "Afroyim v. Rusk" was narrowed by a later case, "Rogers v. Bellei" (1971), in which the Court determined that the Fourteenth Amendment safeguarded citizenship only when a person was born or naturalized in the United States, and that Congress retained authority to regulate the citizenship status of a person who was born outside the United States to an American parent.However, the specific law at issue in "Rogers v. Bellei"—a requirement for a minimum period of U.S. residence that Bellei had failed to satisfy—was repealed by Congress in 1978.