There are statutes in the Immigration Nationality Act that punish willful material misrepresentations/fraud and false claims to citizenship in connection with any benefit under the law (See https://www.law.cornell.edu/uscode/text/8/1182 - INA 1182(a)(6)(C)(i) and INA 1182(a)(6)(C)(ii)).
However, the Board of Immigration Appeals has recognized timely retraction of false statements. The Board has recognized that a timely retraction cures misrepresentations if the applicant voluntary and timely retracts the statement. In a precedential decision in the Matter of M- (BIA 1960) https://casetext.com/admin-law/in-the-matter-of-m-43#p119 the Board has held
We have held that where an alien in an immigration proceeding testifies falsely under oath as to a material fact but voluntarily and without prior exposure of his false testimony comes forward and corrects his testimony, perjury has not been committed and the charge based thereon is not sustained
Does this precedent apply to false claims to citizenship [INA 1182(a)(6)(C)(ii)] where the "proceeding" is non immigration, say applying for a voter id and then immediately retracting the application?
It appears that US Citizenship and Immigration Services recognizes such a defense (https://www.uscis.gov/policy-manual/volume-8-part-k-chapter-2#S-E).
Can the scope of the precedent expand to non immigration proceedings such as applying for a US passport, voter id etc? Is this seen everywhere in law where the holding applies to cases not thought of by the court setting the precedent? What is the rationale for this?