Analysis of information sources in references of the Wikipedia article "Afroyim v. Rusk" in English language version.
Despite his regard for precedent, during his last term [Harlan] also joined a new majority in Rogers v. Bellei, ... which qualified the Court's ruling in the Afroyim case and upheld a regulation providing that persons born outside the United States of a citizen and an alien must satisfy a residency requirement in order to retain their U.S. citizenship.
[L]ess than a decade later ... the Supreme Court overturned Perez v. Brownell, in the no less famous Afroyim v. Rusk.
Later court decisions have cut into the protections afforded by Afroyim. Rogers v. Bellei ... upheld a federal statute revoking the citizenship of children of American citizens born abroad in the event that they failed to reside in the United States for five consecutive years between the ages of 14 and 28.... The court proceeded on the theory that this type of citizenship, granted by statute, was not protected by the fourteenth amendment.
However, because there were concerns that the Civil Rights Act might be subsequently repealed or limited the Congress took steps to include similar language when it considered the draft of the Fourteenth Amendment.
When ... it comes to the attention of a U.S. consular officer that a U.S. citizen has performed an act made potentially expatriating ... the consular officer will simply ask the applicant if there was intent to relinquish U.S. citizenship when performing the act. If the answer is no, the consular officer will certify that it was not the person's intent to relinquish U.S. citizenship and, consequently, find that the person has retained U.S. citizenship.
Only one court ever has examined the substance of TONA [the Titles of Nobility Amendment], and even then only tangentially. In Afroyim v. Rusk, the Supreme Court briefly examined the circumstances surrounding the proposal of TONA in order to determine if they provided any guidance as to whether Congress could enact a law stripping an American of his citizenship without a voluntary renunciation.
When ... it comes to the attention of a U.S. consular officer that a U.S. citizen has performed an act made potentially expatriating ... the consular officer will simply ask the applicant if there was intent to relinquish U.S. citizenship when performing the act. If the answer is no, the consular officer will certify that it was not the person's intent to relinquish U.S. citizenship and, consequently, find that the person has retained U.S. citizenship.