Similarly, habeas corpus challenging the validity of a removal order is not mooted by the deportation.[61]

[61] Zegarra-Gomez v. INS, 314 F.3d 1124 (9th Cir. January 2, 2003) (where a noncitizen habeas petitioner has been deported after filing a habeas corpus petition, the fact of his deportation does not render the petition moot where collateral consequences arising from the deportation create concrete legal disadvantages).

Second Circuit

JUDICIAL REVIEW - FEDERAL - HABEAS - MOOTNESS - REMOVAL DID NOT RENDER MOOT HABEAS ACTION CHALLENGING REMOVAL ORDER ON BASIS THAT CONVICTION DID NOT CONSTITUTE AN AGGRAVATED FELONY
Kamagate v. Ashcroft, 385 F.3d 144 (2d Cir. Sept. 21, 2004) (removal of respondent did not render moot a federal habeas action under 28 U.S.C. 2241 challenging validity of removal order on basis of aggravated felony, since he can show some 'collateral consequence' ... meaning 'some concrete and continuing injury other than the now-ended [threat of removal]' to establish a live case or controversy; noncitizen convicted of a crime of moral turpitude may seek cancellation of removal and thereby avoid permanent inadmissibility, only if he is not an aggravated felon; fact that noncitizen removed as aggravated felon causes ongoing damage sufficient to create case and controversy).

Fifth Circuit

RELIEF - POST-DEPORTATION - VACATE ILLEGAL DEPORTATION ORDER
Zalawadia v. Ashcroft, 371 F.3d 292 (5th Cir. June 4, 2004) (removal of noncitizen while appeal of district court dismissal of habeas petition was pending in court of appeal did not deprive district court of habeas jurisdiction on remand, and case was not moot, but district court lacked authority to grant any relief beyond vacating defective deportation order).