Martinez v. U.S. Atty Gen., 446 F.3d 1219 (11th Cir. Apr. 21, 2006) (exceptional and extremely unusual hardship requirement for non-LPR cancellation of removal is a discretionary issue, and judicial review is therefore barred).
http://caselaw.lp.findlaw.com/data2/circs/11th/0416740p.pdf

Matter of Bautista-Gomez, 23 I. & N. Dec. 893 (BIA 2006) (8 C.F.R. 1003.23(b)(3) (2005), providing an applicant for cancellation of removal under INA 240A(b) must demonstrate statutory eligibility for that relief prior to the service of a notice to appear, applies only to the continuous physical presence requirement and has no bearing on the issues of qualifying relatives, hardship, or good moral character).

Ibarra-Flores v. Gonzales, 439 F.3d 614 (9th Cir. Mar. 6, 2006) (where no actual record of administrative voluntary departure exists, government cannot show that respondent is ineligible for cancellation of removal because continuous presence was interrupted upon administrated VD; respondents testimony is itself insufficient, especially where there was no evidence that the noncitizen knew and accepted the terms of the voluntary departure). http://caselaw.lp.findlaw.com/data2/circs/9th/0471554p.pdf

Peralta v. Gonzales, 441 F.3d 23 (1st Cir. Mar. 23, 2006) (stop-time rule for cancellation of removal applies retroactively to convictions prior to IIRAIRA).

Vietnam is still not accepting deportees, as a categorical matter, except some recent travelers from Vietnam who have valid passports.  The United States cannot currently remove Vietnamese nationals who came here as refugees in the 1970s-1990s, so they have Zadvydas claims. The United States has been attempting to negotiate a repatriation agreement with Vietnam for years, without success. Proposed legislation seeks to reverse Zadvydas.