” Cordova-Soto, No. 10-9569, slip op. at 8 (quoting 8 C.F.R. § 241.8(a)).Cordova-Soto based her argument on the BIA’s decision in Matter of Quilantan, 25 I&N Dec. 285 (BIA 2010), in which the Board held that the “lawful entry” requirement of the INA’s definition of “admitted,” INA § 101(a)(13)(A), refers only to “procedural regularity.” Cordova-Soto, No. 10-9569, slip op. at 10 (discussing Matter of Quilantan, 25 I&N Dec. at 289).

Additionally, as we will discuss, it can sometimes be to an alien’s detriment to be considered to have been “admitted” as an LPR.Key Administrative and Judicial PrecedentsIn the Matter of Areguillin, 17 I&N Dec. 308 (BIA 1980), the Board of Immigration Appeals held that so long as an alien enters the United States after presenting him or herself for inspection and does not make a false claim of U.S. citizenship, he or she will be considered to have been admitted. The Board reaffirmed its precedent from the Matter of Areguillin in the Matter of Quilantan, 25 I&N Dec. 285 (BIA 2010) where it held that admission refers to procedural regularity rather than whether the applicant for admission was actually admissible. The BIA limited the Matter of Quilantan in the Matter of Pinzon, 26 I&N Dec. 189 (BIA 2013) where it held that an alien who gained entry by making a false claim of citizenship had not been admitted.

The BIA disagreed on both issues. First, the Board explained that this case differs from Matter of Quilantan, 25 I&N Dec. 285 (BIA 2010), where it held that an “admission” occurs under INA § 101(a)(13)(A) so long as the noncitizen presents herself for inspection and the immigration officer lets her through. In contrast, “an alien who entered the United States under a false claim of United States citizenship cannot be considered to have been inspected” because such a person “effectively eludes the procedural regularity of inspection by an immigration officer.”