Mendez v. INS, 563 F.2d 956, 958 (9th Cir. 1977) (when a noncitizen is wrongfully deported, or deportation was effectuated by procedurally defective means, 8 U.S.C. 1105(a) does not bar review of the order by the court of appeals even if the noncitizen has left the United States).