The Fifth Circuit has determined that when the Board of Immigration Appeals remands a case solely for consideration of voluntary departure, there is a final order of removal for the purpose of judicial review. Thus, the court had jurisdiction to review the Board of Immigration Appeals decision.
The full text of Holguin-Mendoza v. Lynch can be found here:
http://www.ca5.uscourts.gov/opinions/pub/16/16-60294-CV0.pdf