The Eleventh Circuit has rejected the Board of Immigration Appeals’ decision in Matter of Richmond, which held that a false claim to U.S. citizenship but must be material to the benefit sought in order to render the petitioner inadmissible. The court held that the plain language of the false claim statute does not include a materiality requirement, and as such, the decision in Richmond is not entitled to any deference. “Aliens can make a false representation with the goal of obtaining a benefit, even if the false representation does not help them achieve that goal.”

The full text of Patel v. Attorney General can be found here