 The "Afroyim" decision stated that no one with United States citizenship could be involuntarily deprived of that citizenship.Nevertheless, the Court distinguished a 1971 case, "Rogers v. Bellei", holding in this newer case that individuals who had acquired citizenship via "jus sanguinis", through birth outside the United States to an American parent or parents, could still risk loss of citizenship in various ways, since their citizenship (unlike Afroyim's citizenship) was the result of federal statutes rather than the Citizenship Clause.The statutory provision whereby Bellei lost his citizenship—a U.S. residency requirement which he had failed to satisfy in his youth—was repealed by Congress in 1978; the foreign voting provision, already without effect since "Afroyim", was repealed at the same time.