Matter of Aguilar-Aquino, 24 I. & N. Dec. 747 (BIA Mar. 6, 2009) (release on ankle monitor is not a form of custody sufficiently restrictive to constitute "custody" within the meaning of INA 236 and 8 CFR 1236.1(d), so respondent had already been "released from custody," and the immigration court lacked jurisdiction to redetermine the conditions of release determined in the first instance by the District Director).
jurisdiction:
BIA