The Board of Immigration Appeals has held that United States v. Rivera-Valdes applies in civil removal proceedings, relying on the Ninth Circuit's decision in Meza Medina v. Blanche, but has also held that no further notice efforts were required where a hearing notice was returned as undeliverable and the Immigration Court had no better address for the respondent. The Board also held that Immigration Courts are not suited to locating respondents, citing limited resources, heavy caseloads, the parties' responsibility for address updates under the regulations, and neutrality concerns, and noted that calling the telephone number on the Form I-830 is not a reasonable step because of the risks of improper ex parte communication, difficulty verifying the caller's identity, and confidentiality concerns under 8 U.S.C. § 1367.
The full text of Matter of Jose Israel Chamorro Castillo can be found here: https://www.justice.gov/eoir/media/1467521/dl?inline