In Arsdi v. Holder, 659 F.3d 925 (9th Cir. Oct. 24, 2011), the Ninth Circuit held it lacked jurisdiction to consider petition for review of claim that Immigration Judge used wrong standard to decide whether conviction was for particularly serious crime to bar relief, since the petitioner failed to exhaust the claim by presenting it to the BIA in a way that afforded the BIA notice and a chance to correct its own errors. He made only a general allegation that the IJ erred in denying him relief, and failed to specify which issues form the basis of the appeal. INA 242(d)(1), 8 U.S.C. 1252(d)(1) (court of appeal has jurisdiction to review final removal order only if the petitioner has exhausted all administrative remedies available to the alien as of right.).

The court laid out the general rules governing decision of a claim that a petitioner has failed to exhaust an issue:

Our jurisdiction to hear Arsdi's claim is subject to the strict limits placed by Congress in the Illegal Immigration Reform and Immigrant Responsibility Act of 1996, Pub.L. No. 104"208, 110 Stat. 3009 (1996), and the REAL ID Act of 2005, Pub.L. No. 109"13, 119 Stat. 231 (2005). As such, we have jurisdiction to review only if he has exhausted all administrative remedies available to the alien as of right. 8 U.S.C. 1252(d)(1). If Arsdi did not exhaust his claim that the IJ applied the wrong standard to determine whether his crime was particularly serious, we simply may not review that decision here.

As we have often reiterated, [i]t is a well-known axiom of administrative law that if a petitioner wishes to preserve an issue for appeal, he must first raise it in the proper administrative forum. Barron v. Ashcroft, 358 F.3d 674, 677 (9th Cir.2004) (quoting Tejeda"Mata v. INS, 626 F.2d 721, 726 (9th Cir.1980)). In examining whether the petitioner has met this requirement, we give due regard for the particular administrative scheme at issue. Id. (quoting Weinberger v. Salfi, 422 U.S. 749, 765, 95 S.Ct. 2457, 45 L.Ed.2d 522 (1975)). This rule prevent[s] premature interference with agency processes, so that the agency may function efficiently and so that it may have an opportunity to correct its own errors. Weinberger, 422 U.S. at 765, 95 S.Ct. 2457.
In this administrative scheme, an alien must first appeal any purported errors by the IJ to the BIA, the body to which consistent application of immigration law is primarily entrusted. See 8 C.F.R. 1003.1(b). We have repeatedly held that failure to raise an issue in an appeal to the BIA constitutes a failure to exhaust remedies with respect to that question and *929 deprives this court of jurisdiction to hear the matter. Zara v. Ashcroft, 383 F.3d 927, 930 (9th Cir.2004) (quoting Vargas v. U.S. Dep't of Immigration & Naturalization, 831 F.2d 906, 907"08 (9th Cir.1987)).

(Arsdi v. Holder, 659 F.3d 925, 930 (9th Cir. Oct. 24, 2011).)

The court also stated: As the government points out, an alien may also move for reconsideration or reopening of the IJs decision. See 8 U.S.C. 1229a(c)(6)-(7). Because these motions are not remedies available to the alien, as of right, an alien need not use them in order to exhaust his claim. 8 U.S.C. 1252(d)(1). However, these multifarious methods of review highlight the import Congress placed on allowing the agency to correct its own mistakes prior to interference by the federal courts. (Id. at n.4.)