The Board of Immigration Appeals has held that a certificate of citizenship procured by fraud does not confer citizenship on the applicant.  Thus, the applicant is still subject to charges of removability in an immigration court.  "A certificate of citizenship only provides documentation of United States citizenship for persons who claim to have obtained that status derivatively.  It does not confer United States citizenship but only furnishes recognition and evidence that the applicant has previously obtained such status derivatively, that is, upon the naturalization of a parent or parents.  Thus, the issuance of a certificate of citizenship, like a United States passport, only serves as indicia of citizenship. It is not a grant of United States citizenship.  Because the respondent’s United States citizenship claim was based on fraud, his Certificate of Citizenship is void. Once it was discovered that the respondent’s Certificate of Citizenship had been issued in error, the District Director had an affirmative duty to institute administrative proceedings to cancel it."

The full text of Matter of Falodun can be found here: