 The fact that this 1810 proposal had been framed as a constitutional amendment, rather than an ordinary act of Congress, was seen by the majority as showing that, even before the passage of the Fourteenth Amendment, Congress did not believe that it had the power to revoke anyone's citizenship.The Court further noted that a proposed 1818 act of Congress would have provided a way for citizens to voluntarily relinquish their citizenship, but opponents had argued that Congress had no authority to provide for expatriation.Afroyim's counsel had addressed only the foreign voting question and had carefully avoided any direct challenge to the idea that foreign naturalization might legitimately lead to loss of citizenship (a concept which Warren had been willing to accept in his "Perez" dissent).