Madrigal v. Holder, 572 F.3d 239 (6th Cir. Jul.9, 2009) (deportation by the government did not trigger automatic withdrawal, under 8 C.F.R. 1003.4, of appeal to BIA to review IJ denial of motion to reopen because respondent had not left of her own volition).
ttp://www.ca6.uscourts.gov/opinions.pdf/09a0241p-06.pdf