The United States has a lengthy history of involuntary expatriation. From 1907, naturalized persons who returned to their country of origin for two or more years could be expatriated, as could native-born nationals who moved abroad and took allegiance to another nation. Married women were automatically expatriated upon marriage to foreign men or men who were unable to qualify for naturalization. From 1940, reasons for involuntary termination of nationality included service to a foreign government or in foreign armed forces, voting in a foreign election, military desertion, treason, or evidence of dual nationality, except for possession of a passport. The Supreme Court's interpretation of expatriation was made clear in "Mackenzie v. Hare" in 1915 with the ruling that Ethel Mackenzie's conduct, choosing to marry a non-national, was a voluntary acceptance to be denationalized. In the case of "Savorgnan v. United States" in 1950, the Court ruled that not knowing the consequences of one's actions was equally voluntary expatriation. The 1958 decision in "Perez v. Brownell", which upheld denaturalization for foreign voting, marked a turning point, and the decision was reversed in 1967 in the ruling for "Afroyim v. Rusk", 387 U.S. 253, which found that a for a person's voluntary action to initiate a loss of nationality, an inference of abandonment by the action must have been present. By 1978, the decision in "Vance v. Terrazas" made it clear that a specific intent to expatriate must exist to lose nationality.