Zambrano-Reyes v. Holder

Bd. did not err in denying alien’s request to reopen proceedings regarding his 2000 removal to Mexico where alien had been arrested by immigration officials following his illegal reentry into U.S. While alien argued that his initial removal was in error because he was prevented from seeking discretionary relief under section 212(c) of INA, alien’s illegal reentry into U.S. meant that he was not eligible under 8 USC section 1231(a)(5) to reopen his prior removal proceeding.