In Rangel-Perez, the court recognized that the majority of the courts "lean toward acceptance of the view that the doctrine of collateral estoppel, while available to the accused against the Government is not available to the prosecutor in Federal criminal cases".
In Campos v. U.S. Immigration Naturalization Service, 402 F.2d 758 (9th Cir. 1968), this court interpreted Section 212(a)(4) of the Act, 8 U.S.C. § 1182(a)(4), to apply to both adjustment of status and entry.