Pankajkumar S. Patel v. U.S. Attorney General, 917 F.3d 1319

Patel, an Indian national who entered without inspection, applied for adjustment of status under 8 U.S.C. § 1255(i) as beneficiary of an approved I-140; eligibility required proving he was not inadmissible.
On a 2008 Georgia driver’s license application Patel checked the box stating he was a U.S. citizen; DHS charged inadmissibility under 8 U.S.C. § 1182(a)(6)(C)(ii)(I) for falsely claiming citizenship.
At the removal hearing Patel conceded removability but argued the citizenship check was a mistake (lack of subjective intent) and, alternatively, that citizenship was immaterial because noncitizens can obtain Georgia licenses.
The IJ found Patel not credible, concluded he intentionally misrepresented citizenship and failed to prove he was otherwise eligible for a license; the BIA affirmed (one-member dissent on materiality).
Patel appealed; court treated legal questions de novo but held it lacked jurisdiction to review factual findings bearing on subjective intent because denial of §1255 relief is precluded from factual review by 8 U.S.C. §1252(a)(2).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court may review Patel’s factual claim he accidentally checked the citizen box (subjective intent)	Patel: He lacked requisite intent; it was a mistake; he provided immigration documents to DMV	Government/BIA: Subjective intent is a factual finding for the IJ/BIA; this is a factual challenge barred from review of §1255 denials	Court: No jurisdiction to review factual disputes about intent under §1252(a)(2); cannot reweigh evidence
Whether §1182(a)(6)(C)(ii)(I) requires materiality of the false citizenship claim	Patel: Citizenship was immaterial to obtaining a Georgia license; materiality must be read into the statute to avoid harsh results	Government/BIA (Richmond): BIA required the misrepresentation to be material to the purpose/benefit sought	Court: Statute unambiguous as written; no materiality element required—only falsity + intent to obtain a purpose/benefit under federal or state law

Chevron U.S.A. Inc. v. Natural Res. Def. Council, 467 U.S. 837 (agency deference framework)
INS v. Aguirre-Aguirre, 526 U.S. 415 (agency/Board precedential decisions entitled to Chevron deference)
Kungys v. United States, 485 U.S. 759 (statute applying to false statements for immigration benefits does not distinguish material vs. immaterial lies)
Gonzalez v. U.S. Att'y Gen., 820 F.3d 399 (11th Cir.) (standard of review for BIA decisions)
Silva-Hernandez v. U.S. Bureau of Citizenship & Immigration Servs., 701 F.3d 356 (11th Cir.) (absurdity doctrine narrow exception)
Castro v. Attorney General, 671 F.3d 356 (3d Cir.) (legislative history on false citizenship claims and public benefits)
Kucana v. Holder, 558 U.S. 233 (presumption favoring judicial review of administrative actions)