Bancroft Treaties

The second provided that naturalized citizens who returned to their native country could be prosecuted for crimes that they allegedly committed before they emigrated.

The third and most important provided that naturalized citizens who returned to their country of origin and stayed there for two continuous years would be presumed to have resumed their former nationality.

That would require them to meet any unfulfilled military service obligation in their native country and deny them the diplomatic protection of their adopted one.

[10][11]Conceived in an era when the right of individuals to change their citizenship was not universally recognized, the Bancroft treaties represented an important step forward in securing recognition by foreign governments of the right of their nationals to become American citizens.

These decisions strongly suggested that any future case of involuntary loss of citizenship under one of the Bancroft treaties probably would not survive a Supreme Court challenge.