Xiong v. Gonzales, 484 F.3d 530 (8th Cir. Apr. 12, 2007) (a noncitizen who enters the United States as a refugee, adjust status, and then is convicted of a deportable criminal offense may be placed in removal proceedings even though the DHS has not terminated refugee status), agreeing with Kaganovich v. Gonzales, 470 F.3d 894 (9th Cir.2006); Romanishyn v. Atty. Gen. of the United States, 455 F.3d 175, 180 (3d Cir.2006); Matter of Smriko, 23 I & N Dec. 836 (BIA 2005).