Which of the following is considered a bar to adjustment of status under INA § 245(c)?

The choice related to entering the U.S. without proper documentation is a bar to adjustment of status under INA § 245(c) because it indicates a violation of immigration laws, specifically unauthorized entry. Under this section, individuals who are considered to have entered the United States in violation of immigration laws are generally ineligible to adjust their status to that of a lawful permanent resident. This means that if someone did not enter the U.S. through a lawful process or has previously violated their visa status, they would face restrictions when seeking to change their status.

In contrast, being a lawful permanent resident, having a valid student status, or holding an employment-based visa does not create an adjustment of status barrier under INA § 245(c). Each of these circumstances reflects lawful presence or status in the U.S., which means individuals in these categories are typically eligible to adjust their status, assuming they meet other requisite criteria.