 While Warren was willing to allow for loss of citizenship as a result of foreign naturalization or other actions "by which [an American] manifests allegiance to a foreign state [which] may be so inconsistent with the retention of [U.S.] citizenship as to result in loss of that status", he wrote that "In specifying that any act of voting in a foreign political election results in loss of citizenship, Congress has employed a classification so broad that it encompasses conduct that fails to show a voluntary abandonment of American citizenship.