Toussaint v. Attorney Gen., 455 F.3d 409 (3d Cir. Jul. 26. 2006) (criminal deportees are not recognized as a social group for asylum purposes under United States immigration laws; rejecting asylum claim of Hatian asylum applicant that she would be persecuted in Haiti because she was removed from the United States as a criminal).
http://caselaw.lp.findlaw.com/data2/circs/3rd/053311p.pdf