Splitting from several other circuits who have addressed the issue, the Eleventh Circuit has determined that it lacks jurisdiction to review any sua sponte motion denied by the Board of Immigration Appeals (Board). Even if the Board's decision is based on an error of law, the federal court does not have jurisdiction to review.
The full text of Butka v. Attorney General can be found here:
http://media.ca11.uscourts.gov/opinions/pub/files/201511954.pdf