Kumarasamy v. Atty Gen. of the US, __ F.3d __ (3d Cir. Jun. 23, 2006) (petitioners who have already been removed from the United States do not satisfy the "in custody" requirement for habeas corpus jurisdiction).
http://caselaw.lp.findlaw.com/data2/circs/3rd/052323p.pdf
jurisdiction:
Third Circuit