Kaganovich v. Gonzales, ___ F.3d ___, 2006 WL 3623131 (9th Cir. Dec. 12, 2006) (a noncitizen who arrives in the United States as a refugee may be removed even if their refugee status has never been terminated pursuant to 8 U.S.C. 1157(c)(4)).
http://caselaw.lp.findlaw.com/data2/circs/9th/0470625p.pdf