The Ninth Circuit has determined that a Notice of Appeal that states that an Immigration Judge’s decision was “wrongfully made” was insufficient to put the Board of Immigration Appeals on notice that the appellant was raising a due process claim.
The full text of Santana-Gonzalez v. Bondi can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/04/08/16-70793.pdf