Castro v. Attorney General, 671 F.3d 356 (3d Cir. Feb. 14, 2012) (noncitizen falsely representing himself as a citizen in the course of a police arrest was not for a "purpose or benefit" under federal or state law, for purposes of INA 212(a)(6)(C)(ii), 8 U.S.C. 1182(a)(6)(C)(ii); citizenship status was irrelevant to the police officer to whom the statement was made and there was no evidence that the police would have reported respondent to the DHS); compare Matter of Barcenas"Barrera, 25 I. & N. Dec. 40, 44 (BIA 2009), aff'd sub nom. Barcenas"Barrera v. Holder, 394 F. App'x 100 (5th Cir. 2010), cert. denied, """ U.S. """", 131 S.Ct. 1052, 178 L.Ed.2d 866 (2011) (false claim on a U.S. passport application was for a benefit, the passport, under federal law); Muratoski v. Holder, 622 F.3d 824, 827"29 (7th Cir. 2010); Rodriguez v. Gonzales, 451 F.3d 60, 65 (2d Cir. 2006); Valadez"Munoz v. Holder, 623 F.3d 1304, 1306"07, 1309 (9th Cir. 2010), cert. denied, """ U.S. """", 132 S.Ct. 106, 181 L.Ed.2d 32 (2011); (false claims of U.S. citizenship made orally or in writing to immigration officials for the purpose of gaining entry or admission into the United States); Valenzuela"Solari v. Mukasey, 551 F.3d 53, 54 (1st Cir. 2008); Jamieson v. Gonzales, 424 F.3d 765, 768 (8th Cir. 2005); Kechkar v. Gonzales, 500 F.3d 1080, 1088"84 (10th Cir. 2007) (verifying a job applicant's eligibility to work in the United States); Naser v. Gonzales, 123 F. App'x 624, 624"25 (5th Cir. 2005) (per curiam); Dwumaah v. Attorney General, 609 F.3d 586, 589 (3d Cir. 2010) (per curiam) (upholding BIA determination that an individual was removable for falsely claiming to be a U.S. citizen on an application for a federal student loan, where U.S. citizens are eligible for federal student loans, whereas undocumented immigrants are not, under 20 U.S.C. 1091(a)(5)); but see Hassan v. Holder, 604 F.3d 915, 928"29 (6th Cir. 2010) (government had not established that a false claim to U.S. citizenship made on a Small Business Administration loan application was made for a purpose or benefit under a federal law, since the applicant's immigration status was irrelevant to the loan application, and no evidence suggested that the applicant believed that claiming to be a U.S. citizen would raise the probability that his application would be approved).