Tooby's California Post-Conviction Relief for Immigrants

(C)

Procedural Rules.  A full and unconditional pardon is completely binding for deportation purposes, and cannot be vitiated or ignored by reason of a claim that it had been fraudulently obtained, in the absence of action by the authorities who granted the pardon to revoke the pardon.[161]

The immigration courts need not grant a stay or continuance of deportation to enable the noncitizen to apply for a pardon.  The decision whether to issue a stay is a discretionary one.[162] 

[161] Taran v. United States, 266 F.2d 561 (8th Cir. 1959).

[162] Vermiglio v. Butterfield, 223 F.2d 804 (6th Cir. 1955); Houvardas v. Wixon, 169 F.2d 980 (9th Cir. 1949).