In an unpublished decision, the Tenth Circuit addressed the application of section 212(a)(9)(C) of the Immigration and Nationality (INA) - which defines the immigration consequences of re-entering the United States without admission having previously accrued at least one year of unlawful presence - to minors. The court determined that even though the definition of unlawful presence in section 212(a)(9)(B) of the INA exempts minors from accruing unlawful presence, this exception does not apply to the inadmissibility provision in section 212(a)(9)(C) of the iNA.
The full text of Casillas-Casillas v. Lynch can be found here: