 An amendment proposed by Congress in 1810—the Titles of Nobility Amendment—would, if ratified, have provided that any citizen who accepted any "present, pension, office or emolument" from a foreign country, without the consent of Congress, would "cease to be a citizen of the United States"; however, this amendment was never ratified by a sufficient number of state legislatures and, as a result, never became a part of the Constitution.Ever since the affirmation by Congress, in the Expatriation Act of 1868, that individuals had an inherent right to expatriation (giving up of citizenship), it has historically been accepted that certain actions could result in loss of citizenship.This possibility was noted by the Supreme Court in "United States v. Wong Kim Ark", an 1898 case involving a man born in the United States to Chinese parents who were legally domiciled in the country.