Falsisfication of Citizenship for Private Employment is "Purpose or Benefit" Under the Act

Ferrans v. Holder, 09-3596, concerned a Colombian citizen's petition for review of a decision of the BIA finding him ineligible for relief from removal.  In denying the petition, the court held that the explicit reference to section 1324a in section 1227(a)(3)(D) makes it clear that private employment is a "purpose or benefit" under the Immigration and Nationality Act, and as such, a false representation of citizenship by an alien for the purpose of obtaining private employment is a "purpose or benefit" under the Act, done, at the very least, for the "purpose" of evading section 1324a's provisions.

Related Resource:

• Full text of Ferrans v. Holder