Palomino v. Ashcroft, 354 F.3d 942 (8th Cir. Jan. 15, 2004) (noncitizen disqualified from cancellation of removal, under 8 U.S.C. 1229b(b)(1), on ground that his previous, brief, voluntary departure from the United States under threat of deportation constituted a break in continuous physical presence; 90/180 day limit contained in 8 U.S.C. 1229b(d)(2) is not exclusive definition of break in continuous physical presence).
http://caselaw.lp.findlaw.com/data2/circs/8th/023961p.pdf