Ilchuk v. Attorney General of U.S., 434 F.3d 618 (3d Cir. Jan. 17, 2006) (house arrest with electronic monitoring constitutes "imprisonment" for purposes of deportation under INA 237(a)(2)(A), 8 U.S.C. 1227(a)(2)(A)); Rodriguez v. Lamer, 60 F.3d 745, 749 (11th Cir. 1995) (home confinement may constitute custody); see also Salim v. Reno, 2000 WL 33115910, at *4-*5 (E.D.Pa. Jan.16, 2001) (finding that a convict whose sentence was suspended in favor of mental treatment in a state hospital and later in his home "was sentenced and imprisoned within the meaning of the INA").