Matter of Douglas, 26 I&N Dec. 197 (BIA 2013) (a child who has satisfied the conditions of former section INA 321(a) before turning 18 has acquired United States citizenship, regardless of whether the naturalized parent acquired legal custody of the child before or after the naturalization).

Note that the BIA refused to follow Jordon v. Attorney General of U.S., 424 F.3d
320 (3d Cir. 2005).