(D)  Independent Deportation Ground.  Conviction under 18 U.S.C. § 1546 is also a ground of deportation regardless of the sentence imposed, under a deportation ground independent of the aggravated felony deportation ground, if the offense relates to “fraud and misuse of visas, permits and other entry documents.”[225]  This has been held not to include offenses involving a green card, as it is not primarily a visa or entry document.[226] 

[225] INA § 237(a)(3)(B)(iii), 8 U.S.C. § 1227(a)(3)(B)(iii), discussed at ILRC § 6.8 (2004).

[226] The BIA in an unpublished case followed a Supreme Court case making this distinction.  See Matter of VG, A92 593 325 (Mar. 22, 1999), citing United States v. Campos-Serrano, 404 U.S. 293, 271 (1971).  For a copy of the unpublished BIA decision, contact the National Lawyers Guild National Immigration Project at http://www.nationalimmigrationproject.org or 617-227-9727.  See discussion at ILRC § 6.8 (2004).

Eighth Circuit

AGGRAVATED FELONY - POSSESSION OF UNSIGNED COUNTERFEIT SOCIAL SECURITY CARD
United States v. Pool-Chan, ___ F.3d ___ (8th Cir. Jul. 18, 2006) (federal conviction of possession of counterfeit social security card violates 18 U.S.C. 1546(a), even if the card is not signed). http://caselaw.lp.findlaw.com/data2/circs/8th/054015p.pdf

Other

IMMIGRATION OFFENSES " FEDERAL LAW PREEMPTS STATE IDENTITY FRAUD PROSECUTIONS RELATED TO FEDERAL I-9 FORMS
State v. Reynua, State of Minnesota, Mower County District Court (Jul. 23, 2012) (File No. 50-CR-09-1811) (unpublished) (admission of an I-9 form in a state forgery prosecution was reversible error); on remand after State v. Reynua, 807 N.W.2d 473 (Minn. App. 2011), review granted, revd in part and remanded (Minn. Feb. 28, 2012) (8 U.S.C. 1324a(b)(5) means what it says -- that other than specified federal prosecutions, the I-9 form and appended documents may not be used to establish a state crime).