In the Matter of Richmond, 26 I&N Dec. 779 (BIA 2016), the BIA held that a false claim to U.S. citizenship made to achieve the purpose of avoiding removal proceedings under the INA triggers inadmissibility under section 212(a)(6)(C)(ii)(I) of the INA. The BIA also authoritatively analyzed the statute as a whole.

Invocation of Alien Enemies Act Against Tren de Aragua
President Donald Trump issued a proclamation applying the Alien Enemies Act to Venezuelan members of Tren de Aragua who are neither U.S. citizens nor LPRs.