Immigration, Statutory construction
A material misstatement of fact in an application for a non-immigrant visa constitutes an unlawful procurement of that visa, regardless of whether the fact constituted a statutory bar to the granting of the visa.
http://media.ca11.uscourts.gov/opinions/pub/files/201413767.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.