The Ninth Circuit determined that when the Board of Immigration Appeals (Board) remands a case solely for the purpose of entering an order for voluntary departure, a final order of removal exists, and the court has jurisdiction over an appeal of the Board's decision.
The full decision in Rizo v. Lynch can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2016/01/14/13-74216.pdf