the court followed the decision of "mandoli v. acheson", 344 u.s. 133 in which it had held that "it is settled that no conduct results in expatriation unless the conduct is engaged in voluntarily," a position not challenged by the state department in argument. the court also followed "gonzales v. landon", 350 u.s. 920, where the court had held that the burden of proof in cases of denaturalization under section 401(j) was on the government "by clear, convincing and unequivocal evidence." the court extended this rule to cases under all subsections of section 401. in "schneiderman v. united states", 320 u.s. 118, the court had held that in a case concerning "the precious right of citizenship ... we believe the facts and the law should be construed as far as is reasonably possible in favor of the citizen."