Witter v. INS, 113 F.3d 549, 551 (5th Cir. 1997) (smuggler falsely stated she was married to the illegal alien and presented visas that were procured on the basis of the marriage, which had already been annulled); Vasquez-Araujo v. Ashcroft, 107 Fed.Appx. 155 (9th Cir. 2004) (unpublished) (smuggler drove illegal alien to border where alien presented a false birth certificate supplied by the daughter of the smuggler's girlfriend); In ReL — S____, 22 I. N. Dec. 645, 654 (BIA 1999) (smuggler drove illegal alien in a hidden compartment of a van); In re Compean-Guevara, 21 I. N. Dec. at 52 (smuggler drove the illegal alien across the border and told the official that the alien was a U.S. citizen); Matter of Contreras, 18 I. N. Dec. 30, 30-31 (BIA 1981) (smuggler attempted to re-enter the United States with a man concealed in the back of his vehicle); Matter of Arthur, 16 I. N. Dec. 558, 558 (BIA 1978) (smuggler made "clandestine efforts" to transport illegal aliens across the border); Matter of Valencia-Barajas, 13 I. N. Dec. 369, 370-71 (BIA 1969) (smuggler drove illegal aliens to a point along the Mexican side of the border, where they crossed surreptitiously and without detection, then picked them up on the American side of the border and hid them in his trunk); Matter of Becerra-Miranda, 12 I. N. Dec. 358, 359 (BIA 1967) (smuggler instructed illegal aliens to wait at a point on the Mexican side until they saw his car on the American side, then to cross the border undetected, after which he would drive them away from the border); Cortez-Acosta v. INS, 234 F.3d 476, 483 (9th Cir. 2000) ( reversing a § 212(a)(6)(E) deportation because court doubted that riding as a passenger in one of two vans, when the illegal alien was in the other van, amounted to smuggling); id. ("It is not obvious how Mr. Cortez-Acosta's riding in the car without any illegal aliens would help to smuggle in the illegal alien in the other car."). In a related context, our court has required something more than mere driving for a conviction under the crimin