(D)  Basic Defenses Against Immigration Consequences of Crimes.  Safe havens based on U.S. citizenship, U.S. nationality, or certain American Indian heritage, which provide immunity from adverse immigration consequences, are covered in § § 3.13-3.20, supra.

Sixth Circuit

CONVICTION - COLLATERAL ATTACK IN REMOVAL PROCEEDINGS NOT PERMITTED
Al-Najar v. Mukasey, __ F.3d __, 2008 WL 245632 (6th Cir. Jan. 31, 2008) (petitioner's challenge to the state court conviction in immigration court constituted an impermissible collateral attack).