Afroyim 's counsel had addressed only the foreign voting question .
Afroyim 's counsel had carefully avoided any direct challenge to the idea that foreign naturalization might legitimately lead to loss of citizenship ( a concept which Warren had been willing to accept in his Perez dissent ) .
Afroyim 's counsel had addressed only the foreign voting question and had carefully avoided any direct challenge to the idea that foreign naturalization might legitimately lead to loss of citizenship ( a concept which Warren had been willing to accept in his Perez dissent ) .