The Ninth Circuit has reaffirmed that when the Board of Immigration Appeals (BIA) remands a case to an Immigration Judge solely to address voluntary departure, a final order of removal exists for the purposes of federal court review.  As such, if the non-citizen fails to appeal to the circuit court within 30 days of the BIA's decision, the circuit court lacks jurisdiction to consider any errors in its decision denying other relief.

The full text of Singh v. Lynch can be found here: