The Ninth Circuit recently issued a precedential case that is instructive, and potentially helpful, to individuals accused of making false claims to US citizenship. In Diaz-Jimenez v. Sessions, No. 15-73603 (9th Cir. 2018), the court confirmed that obtaining private employment did fall within the scope of false claims; however, the court also ruled that for purposes of 1182(a)(6)(C)(ii)(I), a person can only be considered to have made a false claim of citizenship in connection with private employment only when such representation is made on Form I-9. In the case at hand, there was no evidence of an I-9 form to sustain the government's claim that Mr. Diaz-Jimenez misrepresented his citizenship status to secure a job, resulting in the court reversing the BIA's finding and remanding the case.