United States v. Ramos-Cruz, 667 F.3d 487 (4th Cir. Jan. 19, 2012) (undocumented noncitizen who applied for, and was denied, TPS prior to being found in possession of a firearm could be convicted as a "alien illegally or unlawfully in the United States" in possession of a firearm; leaving open the question of whether an undocumented noncitizen with TPS pending could be convicted under the same statute).