The Ninth Circuit has determined that a Canadian who was permitted to enter the United States as a passenger in a vehicle through a port of entry has not illegally re-entered the United States for the purpose of reinstatement. The court distinguished this scenario from any situation in which a petitioner uses fraud or other types of deceit to re-enter, noting that Canadians are permitted to enter the United States without visas.
The full text of Tomczkyk v. Wilkinson can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2021/02/03/16-72926.pdf