In a precedential decision addressing a motion to reopen based on lack of notice, the applicant claimed that the immigration officer inappropriately listed an address on the Notice to Appear that the applicant indicated belonged to an acquaintance, but which the applicant did not indicate was his address. Though personally served with the Notice to Appear, the applicant did not attempt to correct the address by filing a change of address form with the Immigration Court. As a result, the notice of hearing was mailed to the address on the Notice to Appear, the applicant did not receive the notice and did not attend his court hearing, and the Immigration Judge ordered the applicant removed in his absence.
Recognizing that the Ninth Circuit had reopened a case under similar circumstances, the Sixth Circuit respectfully disagreed with the Ninth Circuit, and determined that the "fact that the immigration official made the alleged error does not absolve Thompson. Thompson had both the opportunity to provide his current, correct address at the time he received the Notice to Appear and the obligation to ensure that the INS had an address at which he could be reached throughout the proceedings. This obligation necessarily included a duty to correct the address listed on the Notice to Appear, particularly since the Notice to Appear informed him that all future mailings would be sent to the address listed on the form."
The full text of Thompson v. Lynch can be found here: http://www.ca6.uscourts.gov/opinions.pdf/15a0122p-06.pdf