The Eighth Circuit addressed the use of an electronic I-9 form, which pre-populated the applicant's biographical data and selected the US citizen box by default.  Though the petitioner argued that the selection of the U.S. citizen box was accidental, the court found that by submitting the form under penalty of perjury, the petitioner had adopted all the assertions in it.  Because the petitioner had made a false claim to U.S. citizenship, he was not eligible for lawful permanent residence based on his marriage to a U.S. citizen.

The full text of Etenyi v. Lynch can be found here: