 Associate Justice William J. Brennan (who had been in the majority in "Perez") wrote a separate opinion concurring with the majority in "Mendoza-Martinez" and expressing reservations about "Perez".In "Schneider v. Rusk" (1964), where the Court invalidated a provision revoking the citizenship of naturalized citizens who returned to live permanently in their countries of origin, Brennan recused himself and did not participate in the decision of the case.Beys Afroyim (born Ephraim Bernstein, 1893–1984) was an artist and active communist.