The U.S. Supreme Court in Arizona v. United States (2012) held explicitly that “as a general rule, it is not a crime for a removable alien to remain present in the United States.” The key wording, however, is “remain” present - the act of staying in the United States after entry, regardless of whether you knew you were deportable or not, is not a crime even though it may be unlawful (obviously, not every unlawful action is a crime). This means, however, that Arizona does not deal with the issue of improper or unlawful entry.