8 U.S.C. 1252(d)(1) (stating that a court may review a final order of removal only if the alien has exhausted all administrative remedies)



Sanchez-Cruz v. INS, 255 F.3d 775, 779-80 (9th Cir. 2001) (although petitioner's allegation of IJ bias presented a colorable due process claim, the claim was precluded by failure to. present it to the BIA).