Additional crime-related grounds of inadmissibility, such as border crossing,[216] registration fraud,[217] high speed flight from an immigration checkpoint,[218] and the various national security related grounds can be found in Appendix D, infra.  See also § 17.11, supra, for a discussion of relevant non-crime related grounds of deportation, such being inadmissible at time of admission or adjustment, and violation of immigrant status.

[216] INA § 215, 8 U.S.C. § 1185.

[217] INA § 266(c), 8 U.S.C. § 1306(c).

[218] 18 U.S.C. § 758.

BIA

DEPORTATION " VOTING IN FEDERAL ELECTION " STRICT LIABILITY
Matter of Fitzpatrick, 26 I&N Dec. 559 (BIA 2015) (noncitizen who has voted in a federal election, in violation of 18 U.S.C. 611(a), is removable under INA 237(a)(6)(A), 8 U.S.C. 1227(a)(6)(A) (2012), regardless of whether the alien knew that he or she was committing an unlawful act by voting).

DEPORTATION " VOTING IN FEDERAL ELECTION " STRICT LIABILITY
Matter of Fitzpatrick, 26 I&N Dec. 559 (BIA 2015) (noncitizen who has voted in a federal election, in violation of 18 U.S.C. 611(a), is removable under INA 237(a)(6)(A), 8 U.S.C. 1227(a)(6)(A) (2012), regardless of whether the alien knew that he or she was committing an unlawful act by voting). Note: This conviction does not constitute a crime involving moral turpitude, because a scienter of strict liability is insufficiently culpable to qualify. See Leocal v. Ashcroft, 543 U.S. 1 (2004).

Ninth Circuit

DEPORTATION GROUNDS - ILLEGAL VOTING
McDonald v. Gonzales, 400 F.3d 684 (9th Cir. Mar. 2, 2005) ("Ellen Valle McDonald, a native of the Philippines and legal permanent resident of the United States, was found removable under 8 U.S.C. 1227(a)(6)(A) for voting in violation of Hawaii law. Although 1227(a)(6)(A) provides the reason for deportation, we look to the relevant Hawaii statute, H.R.S. 19-3.5(2), to decide whether that reason is substantiated, i.e., whether a violation occurred. Because we determine that McDonald did not have the requisite mental state to have violated H.R.S. 19-3.5(2), we grant her petition.").

Other

RELIEF - NATURALIZATION - ILLEGAL VOTING
See Yates Memo (May 7, 2002), "Procedures for Handling Naturalization Applications of Aliens Who Voted Unlawfully or Falsely Represented Themselves as U.S. Citizens by Voting or Registering to Vote."