The Ninth Circuit finds that the filing of a frivolous asylum application prohibits an applicant from later seeking a waiver of inadmissibility under section 237(a)(1)(H) of the INA. The petitioner filed a frivolous asylum application in 1999 under a false name, and was subsequently granted asylum and permanent residency under his real name. He was later placed in removal proceedings, and sought a waiver under section 237(a)(1)(H), but the agency determined that the filing of a frivolous asylum application in 1999 barred from seeking the waiver. The Ninth Circuit agreed.
The full text of Manhani v. Barr can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2019/11/25/17-72231.pdf