A deeply jarring decision from the Board of Immigration Appeals came out late last month pertaining to the issue of false claims to US Citizenship. Under Section 237(a)(3)(D)(i) of the Immigration and Nationality Act, "an alien who falsely represents, or has falsely represented himself to be a citizen of the United States for any purpose or benefit under this Act (including section 274A) or any Federal or State law is deportable." What makes this case, Matter of Zhang, 27 I & N Dec. 569 (BIA 2019), interesting is that the Board held that a false claim need not necessarily be made knowingly in order to render an individual deportable. Here, Mr. Zhang purchased a naturalization certificate without having undergone the examination, and it was questionable as to whether he knowingly or unknowingly tried to circumvent the process. On appeal, Mr. Zhang maintained that he in good faith believed that he was a US citizen and argued that the government bore the burden of demonstrating that he made the false claim willfully or knowingly.