Lower Courts of Second Circuit

DOCUMENT FRAUD - FALSELY MAKING DOCUMENT
Pena-Rosario v. Reno, 83 F.Supp.2d 349, 366 n.12 (E.D.N.Y. Feb. 8, 2000) (federal conviction for falsely making "document prescribed by statute or regulation as evidence of authorized stay or employment in the United States," in violation of 18 U.S.C. § 1546(a), constituted an "aggravated felony" within meaning of INA § 101(a)(43)(P), 8 U.S.C. 1101(a)(43)(P), for purposes of deportation).

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State v. Reynua, State of Minnesota, Mower County District Court (Jul. 23, 2012) (File No. 50-CR-09-1811) (unpublished) (admission of an I-9 form in a state forgery prosecution was reversible error); on remand after State v. Reynua, 807 N.W.2d 473 (Minn.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).