The Ninth Circuit has determined that false claiming to be a U.S. citizen during a criminal arrest to avoid the initiation of removal proceedings does not trigger the false claim to U.S. citizenship inadmissibility bar. In so doing, the Court determined that Matter of Richmond’s analysis to the contrary is unreasonable and is not entitled to any deference. “Thus, for § 1182(a)(6)(C)(ii)(I) to bar admission into the United States, the noncitizen must have made the false claim of citizenship to comport with some specific legal requirement. Any federal or state law requiring U.S. citizenship will do, but not simply ‘the immigration laws’ generally. And the noncitizen must have intended to obtain a benefit authorized by or achieve a purpose consistent with the specific law at issue. But a noncitizen does not act in accordance with the law by attempting to evade it.”
The full text of Ramirez Munoz v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2023/06/26/21-70431.pdf