The U.S. Supreme Court case Vance v. Terrazas (1979) revolved around the issue of loss of nationality. The court had to decide whether a person could lose their U.S citizenship by voluntarily performing an act that leads to expatriation, even if there was no explicit intention to relinquish citizenship. Lorenzo Terrazas, a dual citizen of the United States and Mexico, signed an oath of allegiance to Mexico which led the State Department to consider him as having renounced his American citizenship under Section 349(a)(2) of the Immigration and Nationality Act. In its decision, however, the Supreme Court ruled in favor of Terrazas stating that intent must be proven for someone's US nationality status can be taken away from them; it cannot simply be presumed from voluntary actions alone. This ruling emphasized that Congress does not have unlimited power when it comes to denationalization laws and affirmed citizens' right against involuntary expatriation.

In the dissenting opinion for Vance v. Terrazas, Justice White argued that Congress has the power to set conditions under which a person can lose their citizenship and that intent to relinquish it can be inferred from one's actions. He disagreed with the majority's view that explicit intention must always be proven in such cases. Instead, he believed there could be circumstances where an individual’s conduct is so inconsistent with allegiance to America that it demonstrates an implicit decision to abandon citizenship. Furthermore, he contended this interpretation was consistent with past Supreme Court decisions on expatriation matters and did not violate constitutional protections against involuntary forfeiture of citizenship rights.