Resendiz v. Kovensky, ___ F.3d ___, 2005 WL 1501495 (9th Cir. June 27, 2005) (immigration custody does not constitute custody sufficient to grant federal habeas jurisdiction sufficient to challenge legal validity of conviction underlying deportation proceedings, after AEDPA and IIRAIRA, so a petitioner may not collaterally attack his state court conviction in a 28 U.S.C. 2241 petition against the INS).
http://caselaw.lp.findlaw.com/data2/circs/9th/0355136p.pdf