 Before heading the ACLU, Ennis had served as general counsel for the INS.In his oral argument supporting Afroyim, Ennis asserted that Congress lacked the power to prescribe forfeiture of citizenship, and he sharply criticized the foreign-relations argument under which the "Perez" court had upheld loss of citizenship for voting in a foreign election—pointing out, for example, that when a referendum was held in 1935 on the status of the Saar (a region of Germany occupied after World War I by the United Kingdom and France), Americans had participated in the voting without raising any concerns within the State Department at the time.Gordon did not make a good showing in the "Afroyim" oral arguments despite his skill and experience in the field of immigration law, according to a 2005 article on the "Afroyim" case by law professor Peter J. Spiro.