In the context of a naturalization case, the Sixth Circuit has determined that a non-citizen is not lawfully admitted to permanent residence if the the admission was not substantively valid. In the instant case, the petitioner was approved for an immigrant visa as a child accompanying or following to join a principal application parent. However, he entered the United States 24 days before his father (the principal applicant). Thus, his lawful permanent residence was accorded in error and he is not eligible for naturalization.
The full text of Turjah v. U.S. Citizenship and Immigration Services can be found here: